From: Barnett.Keith@epamail.epa.gov

Sent: Thursday, April 01, 2010 11:01 AM To: Laney, Michael N. Subject: Emailing: cover letter HCL to Keith.doc, HCL ICR Test Report for Ste Genevieve.pdf, HCL ICR Test Report for Devils Slide.pdf, HCL ICR Test Report for Ada.pdf, Ste Genevieve HCl ICR Site Specific Test Protocol.pdf, Devils Slide HCl ICR Site Specific Test P

Attachments: cover letter HCL to Keith.doc; HCL ICR Test Report for Ste Genevieve.pdf; HCL ICR Test Report for Devils Slide.pdf; HCL ICR Test Report for Ada.pdf; Ste Genevieve HCl ICR Site Specific Test Protocol.pdf; Devils Slide HCl ICR Site Specific Test Protocol.pdf; Ada HCl ICR Site Specific Test Protocol.pdf; HCL ICR Holcim.zip; HOLC IM _ Enclosure 6 M321 Spreadsheet.xls The message is ready to be sent with the following file or link attachments:

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 HCL ICR Test Report for Ste Genevieve.pdf

 HCL ICR Test Report for Devils Slide.pdf

 HCL ICR Test Report for Ada .pdf

 Ste Genevieve HCl ICR Site Specific Test Protocol.pdf

 Devils Slide HCl ICR Site Specific Test Protocol.pdf

 Ada HCl ICR Site Specific Test Protocol.pdf

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Keith W. Barnett USEPA/OAQPS/SPPD/MMG Mail Code D243

- 02 Research Triangle Park, NC 27711 919

- 541

- 5605 barnett.keith@epa.gov (See attached file: cover letter HCL to Keith.doc) (See attached file: HCL ICR Test Report for Ste Genevieve.pdf) (See attached file: HCL ICR Test Report for Devils Slide.pdf) (See attached file: HCL ICR Test Report for Ada.pdf) (See attached file: Ste Genevieve HCl ICR Site Specific Test Protocol.pdf) (See attached file: Devils Slide HCl ICR Site Specific Test Protocol.pdf) (See attached file: Ada HCl ICR Site Specific Test Pr otocol.pdf) (See attached file: HCL ICR Holcim.zip) (See attached file: HOLCIM _ Enclosure 6 M321 Spreadsheet.xls)**DEECO Inc. 3404 Lake Woodard Road**  **Raleigh, NC 27604 (919) 250-0285 (ph); (919) 250-1835 (Fax)**  **www.stacksampling.com**



## Site-Specific Test Plan U.S. EPA Information Collection Request

for Hydrogen Chloride Emissions

from Portland Cement Manufacturing Facilities

**Holcim (US) Inc. - Ada Oklahoma Plant 1100 West 18**  **th Street**  **Ada, Oklahoma 74820**

Submitted By: DEECO, INC. 3404 Lake Woodard Road Raleigh, NC 27603 February 20, 2010

Proposed Test Date: March 12, 2010TABLE OF CONTENTS

Section Page **1.0 INTRODUCTION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1**  **1.1 Summary of Test Program . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1**  **1.2 Test Program Organization . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1** 
**2.0 SOURCE DESCRIPTION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3**  **2.1 Process Description . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3**  **2.2 Control Equipment Description . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3** 
**3.0 TEST PROGRAM . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4**  **3.1 Objectives . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4**  **3.2 Test Matrix . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4** 
**3.3 PROCESS PERFORMANCE INFORMATION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6**  **3.4 Test Coordination . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6** 
**4.0 SAMPLING LOCATIONS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8**  **4.1 Flue Gas Sampling Location . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8** 
**5.0 SAMPLING AND ANALYTICAL PROCEDURES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10**  **5.1 Test Methods . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10**  **5.2 Sampling Point Determination - EPA Method 1 . . . . . . . . . . . . . . . . . . . . . . . . . 10**  **5.3 Flue Gas Velocity and Volumetric Flow Rate - EPA Method 2 . . . . . . . . . . . . . 10**  **5.4 Outlet Flue Gas Composition - EPA Method 3A . . . . . . . . . . . . . . . . . . . . . . . . 10**  **5.5 Flue Gas Moisture Content - EPA Method 4 . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10**  **5.6 Oxygen, Carbon Dioxide, and Hydrogen Chloride - EPA Methods 3A and 321**

**. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11**  **5.6.1 Test Equipment Description . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11**  **5.6.2 Conditioning and Operational Test Periods . . . . . . . . . . . . . . . . . . . . . . . 13 5.6.3 Test Requirements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .**  **. . . . . 13 5.6.4 Test Procedures for EPA Method 3A . . . . . . . . . . . . . . . . . . . . . . . . . . . 13**  **5.6.4 Calibration Gases . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14**  **5.6.5 Test Procedures . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14**  **5.6.6 Data Acquisition . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15**  **5.7 Test Procedures for EPA Method 321 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15**  **6.0 QA/QC ACTIVITIES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17**  **6.1 QC PROCEDURES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17**  **6.1.1 Manual Sampling Equipment . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17**  **6.1.2 Manual Sampling Equipment Calibration . . . . . . . . . . . . . . . . . . . . . . . . 17**  **6.1.3 Manual Sampling Quality Control Procedures . . . . . . . . . . . . . . . . . . . . 22 7.0 REPORTING AND DATA REDUCTION REQUIREMENTS . . . . . . . . . . . . . .**  **. . . . . . . . 25 Format . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .**  **. . . . . . . . . . . . . . . . . 25 7.2 Data Reduction and Summary . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .**  **. . . . . 26**TABLE OF CONTENTS (continued)

Section Page **8.0 PLANT ENTRY AND SAFETY . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 27**  **8.1 Safety Responsibilities . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 27**  **8.2 Safety Program . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 27**  **8.3 Safety Requirements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 27** 
**9.0 PERSONNEL RESPONSIBILITIES AND TEST SCHEDULE . . . . . . . . . . . . . . . . . . . . . 28**  **9.1 Test Site Organization . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 28**  **9.2 Test Preparations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 28**  **9.3 Test Personnel Responsibilities and Detailed Schedule . . . . . . . . . . . . . . . . . . . 28** 

LIST OF TABLES

Table Page **TABLE 3.1 SUMMARY OF SAMPLING AND ANALYTICAL TEST METHODS . . . . . . 5**  **TABLE 3.2 PROGRAM OUTLINE AND TENTATIVE TEST SCHEDULE . . . . . . . . . . . . . 7**  **TABLE 6.1 SUMMARY QA/QC ACTIVITIES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 20**  **TABLE 7.1 EXAMPLE DATA SUMMARY TABLE FOR HYDROGEN CHLOR IDE** 

**EMISSION TEST RESULTS, HOLCIM (US) ADA, OKLAHOMA FACI LITY;**  **MARCH 12, 2010 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 27** 

LIST OF FIGURES Figure Page **Figure 1.1 Organization for Holcim (US) Inc. Ada, Oklahoma Facility HCl ICR Tes t Program** 

**. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2**  **Figure 4.1 Schematic of the Cement Kiln Stack sampling location . . . . . . . . . . . . . . . . . . . . . . . 9**  **Figure 6.1 Example field data sheet for EPA Methods 2 and 4 . . . . . . . . . . . . . . . . . . . . . . . . . . 18**  **Figure 6.2 Example field data sheet for EPA Method 3A . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 19** **HCl ICR Site-Specific Test Protocol Page: 1** 

**Holcim (US) Inc. Revision No: 0**  **Ada, Oklahoma Date: February 20, 2010**  

### 1.0 INTRODUCTION

1.1 Summary of Test Program **The U.S. Environmental Protection Agency (EPA), Office of Air Qua lity Planning and**  **Standards (OAQPS) has issued an Information Collection Request (ICR ) to Holcim (US), Inc**  **(Holcim). Under the authority of Section 114 of the Clean Air Act (C AA). The EPA is requesting**  **information on hydrogen chloride (HCl) emissions from nonhazardous waste-b urning kilns at**  **Portland cement manufacturing facilities. This request is in r esponse to comments from Portland**  **cement industry members and its trade association to EPA’s pro posal to amend the national emission**  **standards for hazardous air pollutants for Portland cement manufact uring (74 FR 21136 (May 6,**  **2009)). Holcim has retained DEECO Inc. (DEECO) to conduct the required emi**  **ssions testing. Testing for HCl will be conducted in accordance with EPA Method 321 -**  **Measurement of Gaseous Hydrogen Chloride Emissions At Portland Cement Kilns by Fourier T**  **ransform Infrared (FTIR) Spectroscopy.**  **The EPA has recognized that the manual sampling techniques for HCl (EPA Methods 26 and**  **26A) may have positive biases due to chloride salts (such as amm onium chloride) that, when**  **collected in the sampling train, for chloride ions (Cl -**  **) that is indistinguishable from the Cl -**  **ion formed upon collection of HCl. In addition, a negative bias may als**  **o exist due to condensation and/or removal of HCl on the filter and/or in the sampling probe.**  **Consequently, the EPA has decided that the FTIR measurement by EPA Method 321 is the prefer**  **red technique for determining the concentration of HCl emissions from nonhazardous waste-burning kilns**  **at Portland cement manufacturing facilities (Source http://www.epa.gov/ttn/atw/pcem/p**  **ortland.pdf). The Holcim facility located in Ada, Oklahoma in Pontotoc County (desig**  **nated as the Ada Oklahoma plant with the physical address of 1100 West 18**  **th Street Ada, Oklahoma 74820) has been**  **one of the Portland cement manufacturing facilities selected as part of the I CR**  **HCl emission tests will be conducted at the main kiln stack. At this fa cility, the emissions**  **from two long, wet kilns are discharged through a single stack. The ceme nt kilns are identified as**  **Cement Kiln #1 (461-KL1) and Kiln #2 (462-KL1) Common Stack Testing is anticipated to be conducted March 12, 2010.** 

1.2 Test Program Organization **Figure 1.1 presents the test program organization, major lines of communication, and names**  **and phone numbers of responsible individuals. HCl ICR Site-Specific Test Protocol**  **Page: 2**

**Holcim (US) Inc. Revision No: 0**  **Ada, Oklahoma Date: February 20, 2010**  **EPA OAQPS, Sector Policies and Programs Division**  **Peter Tsirigotis Research Triangle Institute**  **Contract EP -D-06-118**

**EPA Sector Policies and Programs Division**  **Keith Barnett (919)541-5605**  **Barnett.Keitht@epa.gov Holcim (US), Inc.**  **Corporate Contacts Ruksana Mirza**  **or Hector Ybanez**  **Corporate Manager, Environmental**  **(214) 524 - 2814 Hector.Ybanez@holcim.com**  **Holcim (US), Inc. Environmental Contact**  **Timothy Schlosser (734)529-4118**  **Timothy.Schlosser@holcim.com**

EPA report data contact **Ron Meyers (919) 541-5407**  **myers.ron@epa.gov or**  **Barrett Parker (919) 541-5635**  **parker.barrett@epa.gov Holcim (US) Inc.**  **Ada Oklahoma Plant Ms. Sharon Myers**  **(580) 421-8925 Sharon.Myers@holcim.com**  EPA Test Method contact **Peter Westlin (919) 541-1058**  **westlin.peter@epa.gov**

**or Gary McAllister**  **(919) 541-1062 mcalister.gary@epa.gov**  **DEECO Project Manager Scott Steinsberger**  **(919)250-0285 deeco@deeco.com** 

**DEECO Field Team**

**Figure 1.1 Organization for Holcim (US) Inc. Ada, Oklahoma Facility HCl ICR Tes t Program** **HCl ICR Site-Specific Test Protocol Page: 3** 

**Holcim (US) Inc. Revision No: 0**  **Ada, Oklahoma Date: February 20, 2010**  

### 2.0 SOURCE DESCRIPTION 2.1 Process Description **Holcim (US) operates a facility in Ada, Oklahoma for the manuf acture of portland cement.**  **Facility operations include the operation of two raw mills for raw material processing, the production**  **of clinker in two wet kilns, the operation of a two clinker cooler s ystems, and the operation of two**  **finish mills. Kiln fuels include coal, coke, natural gas, TDF, and whole tires. The airflow from each of the two kilns are directed to two elect**  **rostatic precipitators for particulate removal before exhausting out a single, common stack.** 

2.2 Control Equipment Description **The airflow from each of the two kilns are directed to two elect rostatic precipitators for**  **particulate removal before exhausting out a single, common stack. HCl ICR Site-Specific Test Protocol**  **Page: 4**

**Holcim (US) Inc. Revision No: 0**  **Ada, Oklahoma Date: February 20, 2010**  

### 3.0 TEST PROGRAM

3.1 Objectives **Testing for HCl will be conducted in accordance with EPA Method 321 - Measureme nt of**  **Gaseous Hydrogen Chloride Emissions At Portland Cement Kilns by Four ier Transform Infrared**  **(FTIR) Spectroscopy. The EPA has recognized that the manual sampling techniques for HCl**  **(EPA Methods 26 and 26A) may have positive biases due to chloride salts (such as a**  **mmonium chloride) that, when collected in the sampling train, for chloride ions (Cl**  **- ) that is indistinguishable from the Cl**  **- ion**  **formed upon collection of HCl. In addition, a negative bias may als o exist due to condensation**  **and/or removal of HCl on the filter and/or in the sampling probe. Consequently, the EPA has**  **decided that the FTIR measurement by EPA Method 321 is the prefer red technique for determining**  **the concentration of HCl emissions from nonhazardous waste-burning kilns at Portland cement**  **manufacturing facilities (Source http://www.epa.gov/ttn/atw/pcem/p ortland.pdf).**  **The specific objectives in order of priority are:**

C **Measure the emissions of HCl (EPA Method 321) from the Cement Ki ln Stack during one**  **condition.**

C **Concurrent with the HCl measurements, measure the Cement Kiln St ack volumetric flow**  **rate (EPA Methods 1 and 2), the Cement Kiln Stack oxygen and carbon di oxide content**  **(EPA Method3A), and the Cement Kiln Stack moisture content. Relevant process information will be collected by plant personne**  **l in conjunction with the testing program. The raw process data will be presented a**  **s collected in the appendices of the final report.**  3.2 Test Matrix **Table 3.1 presents the sampling and analytical matrix. HCl ICR Site-Specific Test Protocol**  **Page: 5**

**Holcim (US) Inc. Revision No: 0**  **Ada, Oklahoma Date: February 20, 2010** 

TABLE 3.1 SUMMARY OF SAMPLING AND ANALYTICAL TEST METHODS

Test Parameter Sampling

Method Sample Type Sampling Frequency Analytical Method Measurement Technique

**Volumetric Flow Rate**  **EPA Methods**

**1 and 2 Traverse points;** 

**thermocouple and Pitot tube**  **Concurrent**

**with each Method 321**  **test EPA Method 2** 

**(40 CFR 60, App A) Thermocouple**  **readout and manometer**  **Oxygen and Carbon**  **Dioxide EPA Method** 

**3A Extractive** 

**instrumental sample**  **Concurrent**

**with each Method 321**  **test EPA Method 3A** 

**(40 CFR 60, App A) Paramagnetic**  **for O 2**  **and NDIR for CO**  **2**

**Moisture EPA Method** 

**4 Traverse points;** 

**Condensation Concurrent** 

**with each Method 321**  **test EPA Method 4** 

**(40 CFR 60, App A) Gravimetric** 

**Hydrogen Chloride**  **EPA Method**

**321 Extractive** 

**instrumental sample**  **Three 60-**

**minute test runs per**  **condition EPA Method 321** 

**(40 CFR 63, App A) Fourier**  **Transform Infrared**  **(FTIR) spectrometry** **HCl ICR Site-Specific Test Protocol Page: 6** 

**Holcim (US) Inc. Revision No: 0**  **Ada, Oklahoma Date: February 20, 2010**  3.3 PROCESS PERFORMANCE INFORMATION **Plant personnel in conjunction with the testing program will colle ct process information. The**  **raw process data will be presented as collected in the appendices of the f inal report.** 

3.4 Test Coordination **Ms. Sharon Myers, the Holcim facility contact, will serve as t he test coordinator. She will be**  **responsible for: 1. Scheduling the start of all testing;**  **2. Principal contact with the agency officials concerning the tests; 3. Principal contact with DEECO concerning the tests;**  **4. Recording the process data during the testing; and 5. Providing copies of any field test data to the agency.**  **A tentative test schedule is shown in table 3.2. HCl ICR Site-Specific Test Protocol**  **Page: 7**

**Holcim (US) Inc. Revision No: 0**  **Ada, Oklahoma Date: February 20, 2010**  TABLE 3.2 PROGRAM OUTLINE AND TENTATIVE TEST SCHEDULE Sampling Location Parameter(s) Measured Sampling Method Number of Runs

and Duration Length of

Day(s) Day 1 - March 11, 2010 **Arrive on-site and set up test equipment 8 hours** Day 2 - March 12, 2010 **Kiln Stack Flue Gas Flowrate EPA Methods 1, 2, 4 Three 60-minute**  **runs per condition 10 hours**  **O 2**  **/CO 2**  **EPA Method 3A HCl EPA Method 321**  Day 3 - March 13, 2010 **Contingency Day HCl ICR Site-Specific Test Protocol**  **Page: 8**

**Holcim (US) Inc. Revision No: 0**  **Ada, Oklahoma Date: February 20, 2010**  

### 4.0 SAMPLING LOCATIONS

4.1 Flue Gas Sampling Location **The main stack is a vertically oriented, round stack with an inside diameter of 186 inches. The**  **test location is approximately 130 feet above ground level. Four tes t ports, each four inches in**  **diameter, are located 90** E **apart around the stack circumference. The test ports are loca ted about 6.4**  **equivalent stack diameters downstream and 7.74 equivalent stack diameter s upstream of the nearest**  **flow disturbances. The sampling location meets the minimum spec ifications for selection of a**  **measurement site as outlined in EPA Method 1.**

**A schematic of the Cement Kiln Stack sampling location is shown in Figure 4.1 HCl ICR Site-Specific Test Protocol**  **Page: 9**

**Holcim (US) Inc. Revision No: 0**  **Ada, Oklahoma Date: February 20, 2010** 

**Figure 4.1 Schematic of the Cement Kiln Stack sampling location. HCl ICR Site-Specific Test Protocol**  **Page: 10**

**Holcim (US) Inc. Revision No: 0**  **Ada, Oklahoma Date: February 20, 2010** 



### 5.0 SAMPLING AND ANALYTICAL PROCEDURES

5.1 Test Methods **This section contains a brief description of the sampling and analyti cal procedures for each**  **method that will be employed during the test program. All equipm ent, procedures, and quality**  **assurance measures necessary for completion of the test progra m will meet or exceed the**  **specifications of the appropriate methods. Any deviations fr om the methods to ensure quality**  **representativeness of the results are also discussed.** 5.2 Sampling Point Determination - EPA Method 1 **A minimum eight (8) point velocity traverse will be made in ea ch of two perpendicular**  **directions (4 points in each of the 4 sampling ports). Each tra verse will be made at each sampling**  **location using a type-S pitot tube in accordance with EPA Methods 2 procedures** 5.3 Flue Gas Velocity and Volumetric Flow Rate - EPA Method 2 **The flue gas velocity and volumetric flow rate will be determi ned according to the procedures**  **outlined in EPA Method 2. Velocity measurements will be made using type S pitot tubes conforming**  **to the calibration specifications outlined in EPA Method 2, Section 10.1. Each Type-S pitot tube,**  **calibrated according to these standards, will have an assigned coef ficient. Differential pressures will**  **be measured with Magnehelic gauges of appropriate range or with fl uid manometers. Effluent gas**  **temperatures will be measured with chromel-alumel thermocoupl es equipped with digital readouts.**  5.4 Outlet Flue Gas Composition - EPA Method 3A **Outlet flue gas analysis for oxygen (O 2**  **) and carbon dioxide (CO 2**  **) concentrations, and the calculation of percent excess air and flue gas dry molecular w**  **eight will be performed in accordance with EPA Method 3A. Refer to Section 5.6 for more information** 

5.5 Flue Gas Moisture Content - EPA Method 4 **The flue gas moisture content will be determined in conjunction wit h each sampling run and**  **according to the sampling and analytical procedures outlined in EPA Method 4. The impingers will**  **be connected in series, and contained in an ice bath in order to assure condensation of t he moisture**  **in the flue gas stream. Any moisture that is not condensed in the i mpingers is captured in the silica**  **gel, therefore all moisture can be weighed and entered into moisture content calc ulations.** **HCl ICR Site-Specific Test Protocol Page: 11** 

**Holcim (US) Inc. Revision No: 0**  **Ada, Oklahoma Date: February 20, 2010**  5.6 Oxygen, Carbon Dioxide, and Hydrogen Chloride - EPA Methods 3A and 321 **A CEM system will be used to determine oxygen and carbon dioxide concentrations and**  **hydrogen chloride concentrations on the Main Kiln/Raw Mill stack. The procedures used in meeting**  **these requirements are detailed below.** 5.6.1 Test Equipment Description **The instrumentation and all sampling and analytical procedures that will be used by DEECO**  **for the HCl ICR testing will conform with the requirements of E PA Test Methods 3A and 321 using**  **FTIR. For HCl, the extractive system requires that the effluent gas**  **sample be filtered and maintained at a minimum of 356°F (180°C) prior to being delivered to the FTIR s**  **ample cell. The FTIR sample cell will also be maintained at 356°F. The gas sample will**  **be drawn through the extractive system and the FTIR cell using a heated sample pump. The extractive**  **system will be equipped with a glass lined probe also heated to a minimum of 356°F. The probe will**  **be of sufficient length to reach a minimum of three traverse points at 17, 50, and 83 percent of the duct diameter or 0.4, 1.2,**  **and 2.0 meters from the stack or duct wall, which ever is less. All c**  **omponents of the sampling system which contact the sample will be either of glass, stainless steel, or Teflon**  **The extracted gas sample exiting the heated sample pump wi ll be conditioned to remove**  **moisture with an ice water-cooled condenser. A gas distribution manifold wil l be used to deliver a**  **representative sample of flue gas to oxygen and carbon dioxide analyzers. Fourier Transform Infrared (FTIR) spectroscopy for Hydrogen Chl**  **oride - FTIR spectroscopy**  **measures vapor phase organic or inorganic compounds which absorb ener gy in the mid-infrared**  **spectral region, about 400 to 4000 cm -1**  **(25 to 2.5 μm). Continuous measurement is made by matching sample absorbance bands with bands in reference spect**  **ra, and comparing sample band intensities with reference band intensities.**  **The principle limitation to FTIR spectroscopy are the pres ence of interfering compounds that**  **also absorb energy in the mid-infrared spectral region. In a c ement kiln stack gas matrix, water vapor**  **(H 2**  **O) and carbon dioxide (CO 2**  **) are the primary interferents that must be incorporated i nto the**  **identification and quantitation method. By choosing the proper analytical region(s) for the HCl spectra, the eff**  **ect of the interfering compounds can be minimized. The analytical regions will be sele**  **cted based on examination of the actual stack gas matrix. (It should be noted that the analytica**  **l region provided as an example in EPA Method 321 (2679-2840 cm**  **-1 ) does not correspond with the entire analytical region for HCl (2600-**  **3100 cm -1**  **). The example cited in Method 321 appears to have been copied from the formaldehyde**  **analytical region used as an example in Method 318.) The FTIR software performs the computation for a single compound b**  **y subtracting all the other compounds (interferants and target) from the absorbance spec**  **tra and quantifies the single compound based on the remain absorbance. The FTIR software provides**  **a Standard Error Calculation (SEC) value that is an indication of how well the identi**  **fication and quantitation has been performed. A high SEC indicates that other interferants have not b**  **een accounted for in the analysis HCl ICR Site-Specific Test Protocol**  **Page: 12**

**Holcim (US) Inc. Revision No: 0**  **Ada, Oklahoma Date: February 20, 2010**  **method, and a low SEC is indicative of greater confidence mesurement . Typically, if the reported**  **SEC is greater than half the reported concentration then the results is suspect**

**. A MIDAC I-Series FTIR will be used to determine HCl concent**  **rations according to EPA Method 321. Infrared absorption spectroscopy is performed by directing an infr**  **ared beam through a sample to a detector. The frequency-dependent infrared absorbanc**  **e of the sample is measured by comparing this detector signal (single beam spectrum) to a signal**  **obtained without a sample in the beam path (background). Most molecules absorb infrared radiation and the a**  **bsorbance occurs in a characteristic and reproducible pattern. The infrared spectrum**  **measures fundamental molecular properties and a compound can be identified from its infrared sp**  **ectrum alone. Within constraints, there is a linear relationship between infrared absorption a**  **nd compound concentration. If this frequency dependent relationship (absorptivity) is known (measured),**  **it can be used to determine compound concentration in a sample mixture.**  **Absorptivity is measured by preparing, in the laboratory, standa rd samples of compounds at**  **known concentrations and measuring the FTIR "reference spectra" of these standard samples. These**  **"reference spectra" are then used in sample analysis: (1) compounds are detected by matching sample**  **absorbance bands with bands in reference spectra, and (2) concentra tions are measured by comparing**  **sample band intensities with reference band intensities. Reference spectra for hydrogen chloride and sulfur hexafluoride will**  **be generated from commercially-available calibration gas cylinders. The EPA**  **reference spectra available from the EPA’s Emission Measurement Center are not representative of** **the concentrations (at 189.5 ppm meters and 497.3 ppm-meters) being measured. HCl reference spe**  **ctra at 2 ppm and 5 ppm (16.3 ppm-meters and 40.8 ppm-meters) will be used. Secondly, higher resol**  **ution spectra, compared to the EPA reference spectra, will be necessary due to the low**  **HCl concentrations that are expected and the high moisture levels (up to 35%) that will be encountered. Thir**  **dly, errors have been reported for certain EPA reference spectra, so the entire EPA reference spectra da**  **ta base should be suspect. CAI Model 200 O**  **2 /CO**  **2 Analyzer**  **- The CAI Model 200 O 2**  **/CO 2**  **analyzer houses two measurement principles in one instrument. The oxygen concentrations are measure**  **d using the parapneumatic technique. Because of its sp3 electron orbital distribution, an oxy**  **gen molecule has an unpaired electron and hence displays a magnetic orientation. Since other el**  **ements that display this magnetic phenomenon are not common gasses at normal temperatures, the parap**  **neumatic measurement technique is virtually specific for oxygen. The sample gas flows t**  **hrough a detection cell located in a very strong magnetic field. The magnetic nature of the oxygen cause**  **s the oxygen to move to one side of the detection cell, inducing a pressure differential prop**  **ortional to the oxygen concentration in the detector cell. The analyzer measures this pressure di**  **fferential, converts the pressure differential to an electrical signal, and sends the results as output.**  **The carbon dioxide concentrations are measured using a single -beam photometric system with**  **a micro flow sensor detector. The micro flow detector is a sea led unit filled with carbon dioxide.The**  **instrument consists of an infrared light source, a chopper, a measur ing cell and a micro flow detector**  **filled with carbon dioxide. The infrared light emitted backward is reflected by a reflecting surface**  **and is added to the infrared light emitted forward. Arranged betwe en the infrared light source and**  **the measuring cell is a chopper blade which rotates to modulate the infrared light beam at regular**  **frequency. The modulated infrared light beam thus formed passes thr ough the measuring cell filled**  **with a sample gas where the light energy is partially ab sorbed or attenuated before it reaches the front** **HCl ICR Site-Specific Test Protocol Page: 13** 

**Holcim (US) Inc. Revision No: 0**  **Ada, Oklahoma Date: February 20, 2010**  **chamber of the detector. Both the front and rear chambers of the detector are filled with the gas**  **component to be measured. The infrared light energy is partiall y absorbed in the front chamber and**  **residual light is absorbed in the rear chamber, thereby incre asing the pressure in both chambers.**  **Since the detector is designed to produce a pressure difference b etween the front and rear chambers,**  **a slight gas flow is produced through a path connecting these chambe rs with each other. This slight**  **flow is converted into an AC electrical signal by a micro flow sensor.**

5.6.2 Conditioning and Operational Test Periods **The conditioning and operational test periods will be complete d and sampling commenced**  **once all monitors are found to be acceptable.** 5.6.3 Test Requirements **DEECO's extractive measurement system and all sampling and analytical procedures for**  **testing will conform to the requirements of EPA Methods 2, 3A, and 4 of 40 CFR 60 and EPA**  **Method 321 of 40 CFR 63. The extractive monitors require that the effluent gas sample b**  **e conditioned to eliminate any possible interference (water vapor and particulate matter)**  **before being transported and injected into each analyzer. All components of the sampling system that conta**  **ct the sample are Type 316 stainless steel, glass, or Teflon.**  **A heated probe with an in-stack particulate filter, heated sa mple lines, moisture removal trap,**  **a sample pump, and distribution manifold board are used to deliver a represe ntative sample of flue**  **gas to the analyzers. The sampling probes are constructed of 316 stainless steel and are heated**  **electrically to maintain the sample temperature above the dew point. The sample acquisition and conditioning system also includes two inje**  **ction ports: (1) immediately upstream of the analyzers for analyzer lineari**  **ty checks, and (2) at the outlet of the probe for the sampling system bias and calibration drift checks. Thi**  **s arrangement provides both ease in checking the analyzer performance and a means of evaluating the entire monitoring**  **system.** 5.6.4 Test Procedures for EPA Method 3A **All analyzers will be subjected to an interference check sim ilar to the procedures in Section**  **5.4 of EPA Method 20. During calibration, all analyzers’ response wi ll be noted while introducing**  **each calibration gas. If the sum of the interference responses of the test gases for any of the analyzers**  **is greater than 2 percent of the applicable span value, correct ive measures on the analyzer will be**  **taken, up to and including replacement of the analyzer. Calibration procedures will be performed in accordance with EPA**  **methodology. Analyzers will be calibrated before and after each test and a calibr**  **ation check will be done between each test run.** **HCl ICR Site-Specific Test Protocol Page: 14** 

**Holcim (US) Inc. Revision No: 0**  **Ada, Oklahoma Date: February 20, 2010**  **The pretest calibrations will consist of the following steps: • Internal (direct) calibration of each analyzer to adjust cal**  **ibration and check linearity. • External (through the entire sampling system) calibration to**  **check the system bias on zero and span gases.**  **The post test calibration will consist of an external system bias cal ibration check.** 
5.6.4.1 Internal Calibration **- Each analyzer will be calibrated using a certified zer o and span (mid**  **or high range as necessary) gas. Zero and span gases will be directed to each analyzer through the**  **appropriate plumbing, the calibration gas flow rates will b e adjusted to the correct flow rate and the**  **analyzer will be adjusted with the appropriate span pot. After the analyzer is properly adjusted the**  **linearity will be checked using a mid range calibration gas. The maximum allowable limit for**  **linearity is 2% of the analyzer range. All analyzers will be shown to be linear within these limits**  **before proceeding.**
5.6.3.2 External Calibration **- The external calibration bias check will be performed by placing the**  **CEM system in the sampling mode and injecting a zero and span g as into the sample line at the probe**  **exit. This check will show if there was any sampling system related bias, and also served as a check**  **of the integrity of the sample line.**
5.6.4 Calibration Gases **DEECO will use EPA Protocol #1 gases for calibration as requir ed by the various reference**  **methods used in this test program. Calibration gases will be selected from previous experience with**  **similar sources and/or from information obtained from the facilit y engineer prior to sampling. Audit**  **gases, if available from federal or state agencies, will be analyzed.**
5.6.5 Test Procedures **At the completion of the pretest calibration routine, the CEM sy stem will be ready for**  **operation. No further adjustments of sample flow rates, analyz er zero or span adjustments, or other**  **critical CEM operating parameters will be made until te sting and post test calibration are complete.**  **The CEMs will be allowed to at least 21 minutes to complete e ach test run. At the completion for**  **each run, calibration gases nearest to the measured emission le vels will be used to check each**  **instrument. During each sampling run, a sampling traverse will be perfor**  **med to ensure the absence of stratification. Traverse points will be selected that assur**  **e acquisition of representative samples over the stack or duct cross section. A minimum requirement is the esta**  **blishment of a "measurement line" that passes through the centroidal area and in the direction of any e**  **xpected stratification. If this line interferes with the CEM measurements, the line will be displ**  **aced up to 30 cm (12 in.) (or 5 percent of the equivalent diameter of the cross section, whichever is less)**  **from the centroidal area. Per Section 6.5.6.3(a) of 40 CFR 75, three traverse points will be located 16.7,**  **50.0, and 83.3 percent of the measurement line, and measured equally during each run. Alternatively, per Se**  **ction 6.5.6.3(b) of 40 CFR 75, a single sampling point may be used if the concentra**  **tion of each compound at each individual traverse point differs by no more than ±5.0 percent from t**  **he arithmetic average concentration for all traverse points.** **HCl ICR Site-Specific Test Protocol Page: 15** 

**Holcim (US) Inc. Revision No: 0**  **Ada, Oklahoma Date: February 20, 2010**  **Concurrent measurements of flow following EPA Methods 1, 2, 3A, and 4 (Sec tions 5.1**  **through 5.5) will be used to determine flue gas emission rates of all target comp ounds.**  5.6.6 Data Acquisition **Data will be recorded on two separate devices. A hard copy wi ll be obtained using a Molytek**  **2702 strip chart recorder. Data will also be recorded to the hard disk of an IBM compatible computer**  **utilizing the serial output of the Molytek recorder in conjunction wi th custom software. Data for each**  **of the analyzers will be sampled each second with a one-minute a verage being written to disk. Data**  **will be further averaged over the test period and corrected f or calibration error and drift using a**  **spreadsheet program.**

5.7 Test Procedures for EPA Method 321 **The FTIR optics and sample cell will be purged with nitrog en overnight. A backgroung**  **spectra will be collected will purging nitrogen thorough the cel l at a flow rate low enough that the cell**  **pressure is not elevated above ambient pressure. Next an ethy lene Calibration Transfer Standard**  **(CTS) will be passed thorough the cell, again at a flow rate low enough that the cell pressure is not**  **elevated above ambient pressure, and spectra will be collecte d of the CTS gas. By setting the cell**  **pressure in the software to reflect the ambient pressure, the path length can be verified and adjusted**  **as needed. As part of the HCl analyte spiking procedure, the calibration g**  **as mixture containing HCl and sulfur hexafluoride (SF**  **6 ) will then be passed directly to the cell, again at a flow**  **rate low enough that the cell pressure is not elevated above ambient pressure.**  **This will establish the undiluted concentration of the HCl/SF**  **6 mixture to be used in the analyte spike recovery calculations.**  **Next the heated sample line will be connected directly to the sample cell, and stack gas will**  **be drawn through the cell prior to the pretest analyte spiking. The first step in the analyte spiking will be to send the CTS**  **to the sample probe and back through the sampling system. Spectra of the CTS gas will be**  **collected and the cell pressure setting in the software will be adjusted as needed to provide the correct CTS reading.**  **After the CTS check is completed, stack gas will again be sa mpled to provide a pre-spike**  **native concentration of HCl. Next the HCl/SF**  **6 gas mixture will be directed to the sample probe at a f**  **low rate approximately 10% of the total sample rate such that the stack**  **gas provides a nominal 10-fold dilution of the analyte spike. Once a satisfactory spike recovery**  **of 70%-130% has been is achieved, the HCl/SF**  **6 gas mixture will be turned off. The HCl/SF**  **6 spike will be purged from the system and**  **additional spectra will be collected from the stack gas to det ermine the post spike concentration of**  **the native HCl. HCl ICR Site-Specific Test Protocol**  **Page: 16**

**Holcim (US) Inc. Revision No: 0**  **Ada, Oklahoma Date: February 20, 2010**  **It should be noted that there are errors in the Method 321 equation used to calculate the**  **analyte spike recovery. Consequently the following correct equation will be used;**



### % R C C DF C DF t n

s 

### = − −      

× × **1 1** 

**1 100** 

**%R = Spike Recovery C**  **t = Concentration of the total HCl (spike plus native), ppm,**  **C n**  **= Average concentration of the native HCl (pre and post spike), ppm, C**  **s = Concentration of the HCl spike, ppm; and**  **DF = Ratio of the undiluted SF 6**  **tracer gas concentration to the diluted SF 6**  **measured during**

**analyte spiking HCl ICR Site-Specific Test Protocol**  **Page: 17**

**Holcim (US) Inc. Revision No: 0**  **Ada, Oklahoma Date: February 20, 2010**  

### 6.0 QA/QC ACTIVITIES 6.1 QC PROCEDURES **Example data sheets for EPA Methods 2 and 4 and EPA Method 3A are p rovided in Figures**  **6.1 and 6.2. Specific QA/QC parameters for each method is provided in Tabl**  **e 6.1 and described in detail below.**  6.1.1 Manual Sampling Equipment **Each item of field test equipment will be assigned a unique, per manent identification number.**  **An effective preventative maintenance program is necessary to ensure data quality. Each item of**  **equipment returning from the field will be inspected before it is returned to storage. During the**  **course of these inspections, items are cleaned, repaired, reconditi oned, and recalibrated where**  **necessary. Each item of equipment transported to the field for this test pr**  **ogram will be inspected again before being packed to detect equipment problems which may orig**  **inate during periods of storage. This minimizes lost time on the job site due to equipment failure.**  **Occasional equipment failure in the field is unavoidable despite t he most rigorous inspection**  **and maintenance procedures. For this reason, replacement equipment f or all critical sampling train**  **components will be transported to the job site.** 6.1.2 Manual Sampling Equipment Calibration **New items for which calibration is required will be calibra ted before initial field use.**  **Equipment whose calibration status may change with use or time w ill be inspected in the field before**  **testing begins and again upon return from each field use. When an i tem of equipment is found to be**  **out of calibration, it will be repaired and recalibrated or re tired from service. All equipment will be**  **periodically recalibrated in full, regardless of the outcome of these regula r inspections.**  **Calibrations will be conducted in a manner, and at a frequency, which meets or exceeds U.S.**  **EPA specifications. The calibration procedures outlined in the EP A Methods will be followed.**  **When these methods are inapplicable, methods such as those prescrib ed by the American Society for**  **Testing Materials (ASTM) will be used. Data obtained during calibrations will be recorded on standardize**  **d forms, which will be checked for completeness and accuracy by the quality assurance ma**  **nager. Data reduction and subsequent calculations will be performed using computer facili**  **ties. Calculations will be checked at least twice for accuracy. Copies of calibration forms will be incl**  **uded in the final test report. Emissions sampling equipment requiring calibration includes pitot**  **tubes, pressure gauges, thermometers, dry gas meters and barometers. The following sec**  **tions elaborate on the calibration procedures to be followed for these items of equipment.** **HCl ICR Site-Specific Test Protocol Page: 18** 

**Holcim (US) Inc. Revision No: 0**  **Ada, Oklahoma Date: February 20, 2010** 

**Flow rate and Moisture Measurement Data Sheet** Plant and City Date Sampling Location Sample Type Run N o.

Operator Barometric

Pressure (Pb) (In. Hg) Static

Press (in. H2O) Ambient

Temp (deg. F) Stack

ID (In.) Pitot

Cp DGM Box No. DGM delta H@ DGM Cal

Factor (gamma) Probe

ID No. **EPA Method 3/3A Data EPA Method 4 Impinger Weights Oxygen, % Impinger 1 2 3 Sil.Gel**  **Carbon Dioxide, % Final Wt., g Color**  **Nitrogen, % Initial Wt., g % Spent**  **Net Wt., g Total Collected , g**  **EPA Method 2 Data EPA Method 4 Sampling Data**

Run Time (24 hr) Port/Point

ID Pitot

delta P (in. H2O) Stack

Temp (deg. F) Run Time

(24 hr) DGM Reading (cu.ft.) DGM delta H (in. H2O) DGM

Temps (deg. F) Exit

Temp (deg. F) Sample

Train Vac. (In. Hg)

**Initial Leak Rate cfm @ “Hg Final Leak Rate cfm @ “Hg** 

**Pitot Leak Check**

**Figure 6.1 Example field data sheet for EPA Methods 2 and 4 HCl ICR Site-Specific Test Protocol**  **Page: 19**

**Holcim (US) Inc. Revision No: 0**  **Ada, Oklahoma Date: February 20, 2010**  **Plant and City Test Location Date Operator**

**Cylinder ID**  **Gas**

**Type Value Internal**  **Response Cal** 

**Error Run No. Run Time** 

**Pre Run Bias**  **Percent**

**Bias Post Run** 

**Bias Percent** 

**Bias Percent** 

**Drift O**  **2 Zero Zero N**  **2 CC5134 O**  **2 Mid 11.9%**  **CC117302 O 2**  **Span 21.9%**

**CO 2**  **Zero Zero N 2**  **CC5134 CO 2**  **Mid 20.4% CC117302 CO**  **2 Span 35.5%** 

**Figure 6.2 Example field data sheet for EPA Method 3A HCl ICR Site-Specific Test Protocol**  **Page: 20**

**Holcim (US) Inc. Revision No: 0**  **Ada, Oklahoma Date: February 20, 2010**  TABLE 6.1 SUMMARY QA/QC ACTIVITIES Test Equipment QC Parameter Target **Volumetric Flow Rate Measurement Pitot Tube Pitot Geometry Within Specifications**  **Thermocouple <1.5% absolute Pitot Leak Check stable 15 sec at**  $ **4 in. WC Dry Gas Meters for Particulate Sampling**  **Dry Gas Meters Initial Calibration 0.95** # **γ** # **1.05 individual γ RSD**  # **2% Post Test Calibration Check Post test γ**  # **5% Post Test Leak Checks <2% of sample rate**  **EPA Method 3A Initial Calibration Zero Gas <2% of Span Gas**  **Mid Range Gas <2% of Span Gas Span Gas <2% of Span Gas**  **Bias Checks Zero Gas <5% of Span Gas Mid Range Gas <5% of Span Gas**  **Drift Zero Gas <5% of Span Gas Mid Range Gas <5% of Span Gas**  **Method 321 for Hydrogen Chloride Pre/Post CTS Calibration Precision Pre and post quant**  **ification** # **5% RSD Direct HCl Calibration Precision Duplicate measuremen**  **t** # **5% RSD HCl Analyte Spike System Validation Spike Recovery 70**  **% - 130% HCl ICR Site-Specific Test Protocol**  **Page: 21**

**Holcim (US) Inc. Revision No: 0**  **Ada, Oklahoma Date: February 20, 2010**  A: Pitot Tubes. **All Type S pitot tubes used, whether separate or attached to a sampling**  **probe, will be constructed in-house or by a third-party vendor. Eac h new pitot will be**  **calibrated in accordance with Section 10.1 of EPA Method 2. Each Type -S pitot tube,**  **calibrated according to these standards, will have an assigned coe fficient. This**  **coefficient should not change as long as the pitot tube is not damaged. Each pitot tube will be inspected visually upon return f**  **rom the field. If a cursory inspection indicates damage or raises doubt that the pitot rema**  **ins in accordance with the EPA geometry standards, the pitot tube will be refurbis**  **hed as needed and recalibrated.**  B: Differential Pressure Gauge. **All meter consoles used are equipped with 10-inch water column (W.C.) inclined-vertical manometers. Fluid manometers**  **do not require calibration other than leak checks. Manometers will be leak chec**  **ked in the field prior to each test series, and again upon return from the field.**  C: Impinger Thermometer. **Prior to the start of testing, the thermocouple used to monitor the temperature of the gas leaving the last impinger w**  **ill be compared with a mercury-in-glass thermometer which meets ASTM E-1 No. 63F spec**  **ifications. The impinger thermocouple is replaced if it does not agree within**  **2** E **F of the reference thermometer. After each field use, the thermocouple will be c**  **hecked per EPA Alt-011 procedures.**  D: Dry Gas Meter Thermometer. **The thermocouple used to measure the temperature of the metered gas sample will be checked prior to initial f**  **ield use against an ASTM mercury-in-glass thermometer. The dry gas meter thermocouple**  **is acceptable if the values agree within ±2**  E **F. Thermocouples not meeting this requirement will be replaced. After each field use, the thermocouple will be checked**  **per EPA Alt-0011 procedures.**  E: Flue Gas Temperature Sensor. **All thermocouples employed for the measurement of flue gas temperature are calibrated upon receipt. Initi**  **al calibrations will be performed at three points (ice bath, boiling water, and hot oil).**  **An ASTM mercury-in glass thermometer will be used as a reference. The thermocou**  **ple is acceptable if the agreement is within 1.5 percent (absolute) at each of the thre**  **e calibration points. After each field use, the thermocouple will be checked per EPA**  **Alt-011 procedures. Before each field use, the reading from the flue gas thermocouple**  **-potentiometer combination will be compared with an ASTM mercury-in-glass**  **reference thermometer at ambient conditions. If the two agree within ±1.5 pe**  **rcent (absolute), the thermocouple and potentiometer are considered to be in proper working order** 

**.** F: Dry Gas Meter and Orifice. **Two procedures will be used to calibrate the dry gas meter and orifice simultaneously. The full calibration will be**  **a complete laboratory procedure used to obtain the calibration factor of the dry gas me**  **ter. Full calibrations will be performed over a wide range of orifice settings. A s**  **impler procedure, the post test calibration, will be designed to check whether the calibra**  **tion factor has changed. HCl ICR Site-Specific Test Protocol**  **Page: 22**

**Holcim (US) Inc. Revision No: 0**  **Ada, Oklahoma Date: February 20, 2010** 

**A dry gas meter that is calibrated annually against a spir ometer or a set of calibrated**  **critical orifices will be used as a transfer standard. Duri ng the annual calibration,**  **triplicate calibration runs will be performed at seven flow rates ranging from 0.25 to**  **1.40 cfm.** G: Dry Gas Meter. **Each metering system receives a full calibration at the time of**  **purchase and a post-test calibration after each field use. I f the calibration factor, γ,**  **deviates by less than five percent from the initial value, the test data are acceptable.**  **If γ deviates by more than 5 percent, the meter is recalibra ted and the meter coefficient**  **(initial or recalibrated) that yields the lowest sample volum e for the test runs is used.**  **EPA Method 5 requires another full calibration anytime the post- test calibration check**  **indicates that γ changed by more than 5 percent. Standard practice is to adjust and**  **recalibrate the dry gas meter anytime γ is found to be outside the range of 0.96 to 1.04.**  **Post-test calibrations will be performed after each field test series per EPA Alt-009**  **procedures.**

H: Orifice. **An orifice calibration factor will be calculated for each flow setting during**  **a full calibration. If the range of values does not vary by more than 0.15 in H**  **2 O over**  **the range of 0.5 to 4.0 in H 2**  **O, the arithmetic average of the values obtained during the calibration is used.** 

I: Barometer. **Each field barometer will be adjusted before each test s eries to agree**  **within ±0.1 inches of a reference mercury-column barometer. The reference**  **barometer will be checked against the station pressure value ( corrected for elevation**  **difference) reported by the National Weather Service.** 6.1.3 Manual Sampling Quality Control Procedures **The following pretest QC checks will be conducted: • All sampling equipment will be thoroughly checked to ensure clea**  **n and operable components.**  **• Equipment will be inspected for possible damage from shipment. • The oil manometer or Magnehelic gauge used to measure pressure**  **across the Type S pitot tube will be leveled and zeroed.**  **• The number and location of the sampling traverse points will be checked before taking**  **measurements. • The temperature measurement system will be visually c**  **hecked for damage and operability by measuring the ambient temperature prior to each run.**  **In addition to the general QC procedures listed above, QC procedures specific to each**  **sampling method will also be incorporated into the sampling scheme. Thes e methods and specific**  **procedures are discussed below. HCl ICR Site-Specific Test Protocol**  **Page: 23**

**Holcim (US) Inc. Revision No: 0**  **Ada, Oklahoma Date: February 20, 2010**  **A: Sampling Train QC checks. The following QC procedures will be emphasiz ed:**  Prior to Start of Tests **• Keep all cleaned glassware and sample train components se aled until train**  **assembly. • Assemble the sampling trains in an environment free from contamination.**  **• Visually inspect each sampling train for proper assembly. • Perform pretest calculations to determine the proper sampling nozz**  **le size.**

Prior to Each Test Run **• Visually inspect the sampling nozzle. • Visually inspect the Type S pitot tube.**  **• Leak check each leg of the Type S pitot tube. • Leak check the entire sampling train.**  During Each Test Run **• Readings of temperature and differential pressure will be taken at each**  **traverse point. • All sampling data and calculations will be recorded on p**  **reformatted data sheets.**  **• All sampling data forms will be reviewed for completeness and accurac y.**  **• Any unusual occurrences will be noted during each run on the appropr iate data**  **form. • The project supervisor will review sampling data sheet**  **s daily during testing. • Properly maintain the roll and pitch axis of the Type S p**  **itot tube and the sampling nozzle.**  **• Leak check the train before and after any move from one samp ling port to**  **another during a run (at DEECO’s option) or if a filter change takes place. • Maintain the probe, filter, and impingers at the proper temperatur**  **es. • Maintain ice in the ice bath at all times.**  **• Make proper readings of the dry gas meter, delta P and delt a H, temperature,**  **and pump vacuum during sampling at each traverse point. • Maintain isokinetic sampling within ± 10% of 100%.**  After Each Test Run **• Visually inspect the sampling nozzle. • Visually inspect the Type S pitot tube.**  **• Leak check each leg of the Type S pitot tube. • Leak check the entire sampling train.**  **B: QC for Volumetric air flow rate determinations HCl ICR Site-Specific Test Protocol**  **Page: 24**

**Holcim (US) Inc. Revision No: 0**  **Ada, Oklahoma Date: February 20, 2010** 

Flue Gas Velocity. **Data required to determine the flue gas velocity will be col lected**  **using the methodology specified in EPA Method 2. Quality control proce dures are**  **as follows. • Visually inspect the Type S pitot tube before and after sampling.**  **• Leak check both legs of the pitot tube before and after sampling. • Check the number and location of the sampling traverse points bef**  **ore taking measurements.**  Flue Gas Molecular Weight. **Samples to be used for determination of flue gas molecular weight will be collected using the continuous sampling t**  **echnique specified in EPA Method 3A. Quality control will focus on the following procedures:**  **• The sample acquisition system will be leak checked before operation. • A constant sampling rate will be used in withdrawing a sample.**  **• The sampling port will be properly sealed to prevent air in-lea kage.** 

Moisture Content. **The moisture content of the gas stream will be determined usi ng**  **the technique specified in EPA Method 4. The following QC checks wil l be**  **performed: • The sampling train will be leak checked before and after each run.**  **• Ice will be maintained in the ice bath throughout each run. HCl ICR Site-Specific Test Protocol**  **Page: 25**

**Holcim (US) Inc. Revision No: 0**  **Ada, Oklahoma Date: February 20, 2010**  

### 7.0 REPORTING AND DATA REDUCTION REQUIREMENTS 7.1 Report Format

**TABLE OF CONTENTS 1.0 Introduction**  **1.1 Summary of Test Program . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . X**  **1.2 Key Personnel . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . X**  **2.0 Source and Sampling Location Descriptions 2.1 Process Description . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .**  **. . . . . . . . X 2.2 Control Equipment Description . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .**  **. . . X 2.3 Flue Gas and Process Sampling Locations . . . . . . . . . . . . . . . . . . . . . . . .**  **X 3.0 Summary and Discussion of Results**  **3.1 Objectives and Test Matrix . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . X**  **3.2 Field Test Changes and Problems . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . X**  **3.3 Summary of Results . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . X**  **4.0 Sampling and Analytical Procedures 4.1 Emission Test Methods . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .**  **. . . X 4.2 Process Test Methods . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .**  **. . . . X 5.0 QA/QC Activities . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .**  **. . . . . . . . . . . . . . X**
**APPENDICES A - Results and Calculations**  **B - Raw Field Data C - CEM Results**  **D - FTIR Results E - Equipment Calibration Data Sheets and Calibration Certificates of Ana**  **lysis F - List of Participants** **HCl ICR Site-Specific Test Protocol Page: 26** 

**Holcim (US) Inc. Revision No: 0**  **Ada, Oklahoma Date: February 20, 2010**  7.2 Data Reduction and Summary **An example data summary table is shown as Table 7.1.**

TABLE 7.1 EXAMPLE DATA SUMMARY TABLE FOR HYDROGEN CHLOR IDE

EMISSION TEST RESULTS, HOLCIM (US) ADA, OKLAHOMA FACI LITY; MARCH 12, 2010 Test Parameter Run X Run X Run X Average **Time xx:xx-xx:xx xx:xx-xx:xx xx:xx-xx:xx ----**  **Stack Gas Temperature (** E **F) xxx xxx xxx xxx Stack Gas Moisture x.x% x.x% x.x% x.x%**  **Volumetric Flowrate actual cfm**  **dry standard cfm xxx,xxx**  **xxx,xxx xxx,xxx** 

**xxx,xxx xxx,xxx** 

**xxx,xxx xxx,xxx** 

**xxx,xxx Oxygen Content x.x% x.x% x.x% x.x%**  **Hydrogen Chloride Emissions Concentration, ppm**  **by volume, wet basis Concentration, ppm**  **by volume, dry basis Concentration, ppm at 7% oxygen**  **x.xx x.xx**  **x.xx x.xx** 

**x.xx x.xx**  **x.xx**

**x.xx x.xx**  **x.xx**

**x.xx x.xx** **HCl ICR Site-Specific Test Protocol Page: 27** 

**Holcim (US) Inc. Revision No: 0**  **Ada, Oklahoma Date: February 20, 2010** 



### 8.0 PLANT ENTRY AND SAFETY

8.1 Safety Responsibilities **The DEECO Safety Officer (Dr. Scott Steinsberger) is resp onsible for ensuring compliance**  **with plant entry, health, and safety requirements. The Holcim Devils Slide Plant Contact (Sharon Myers) has the aut**  **hority to impose or waive facility restrictions.**  **The DEECO Test Director (Dr. Scott Steinsberger) has authori ty to negotiate with facility**  **person any deviations from the facility restrictions.** 8.2 Safety Program **The DEECO Health and Safety Program is attched as Appendix A.** 8.3 Safety Requirements

**All test personnel will adhere to the following standard safety and precautionary measures**  **as follows:**

C **Confine selves to test area only.**

C **Wear hard hats at all times on-site, except inside sample r ecovery trailers**  **and mobile CEM laboratory.**

C **Wear protective shoes or boots in test area.**

C **Wear protective glasses or goggles at the test sites, and other areas as**  **designated.**

C **Have readily available first aid equipment and fire extinguishers. Before or on the first day on-site, the Test Director will**  **fill out the Holcim Contractor Job Safety Plan and the Pre-Shift Hazard Assessme**  **nt form and provide copies to be posted at each test site.** **HCl ICR Site-Specific Test Protocol Page: 28** 

**Holcim (US) Inc. Revision No: 0**  **Ada, Oklahoma Date: February 20, 2010**  

### 9.0 PERSONNEL RESPONSIBILITIES AND TEST SCHEDULE

9.1 Test Site Organization **The key tasks and task leaders are:**

C **Management:** William G. DeWeeS

C **Test Preparation/Site Restoration:** Scott C. Steinsberger

C **Modifications to Facility/Services:** Sharon Myers

C **Sampling Site Accessibility:** Sharon Myers

C **Sample Recovery:** Marc Hamilton

C **Daily Sampling Schedule:** Scott C. Steinsberger 9.2 Test Preparations **No special sampling and analytical equipment is needed. No modifi cations to the facility are**  **needed. Suitable safe access to the sampling location currently exists. Holcim will provide the**  **necessary electrical power. Sample recovery of the Method 4 tr ains will be conducted in a mobile**  **recovery laboratory already on-site.** 9.3 Test Personnel Responsibilities and Detailed Schedule **DEECO personnel will arrive at the plant about 1.5 hours before the start of the first test run**  **on each of the two days scheduled for sampling. Pre-test activities on these days wi ll include:** 

C **Meet with the plant contact to review the daily test objectives.**

C **Prepare and set-up (including leak checks) the manual method trains at all test locations.** 

C **Calibrate instrumental analyzers and verify that the data ac quisition systems are**  **functioning properly.**

C **Verify communication links between team members/leaders/plant per sonnel.** 

## Appendix A DEECO Health and Safety Plan**DEECO Inc. 3404 Lake Woodard Road**  **Raleigh, NC 27604 (919) 250-0285 (ph); (919) 250-1835 (Fax) www.stacksampling.com** 

**DEECO**
**HEALTH AND SAFETY PLAN**

**January 2010 DEECO**  Health and Safety Plan

**Section Page**  **1.0 Introduction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1**  **1.1 Responsibilities . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1**  **1.2 Employee Conduct . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2**  **1.3 Pre-Work Safety Considerations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4**  **1.4 Employee Safety Education, Training, and Evaluation . . . . . . . . . . . . . . . . . . . . . 4**  **2.0 General Safety Requirements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7**  **2.1 First Aid for Accidents and Injuries . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7**  **2.2 Audit/Inspection Procedures . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8**  **2.3 Bloodborne Pathogens . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9**  **2.4 Aerial Devices (Man Lifts) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9**  **2.5 Confined Space Entry . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11**  **2.6 Documented Safety Meetings . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11**  **2.8 Electrical - GFCI or Grounding Program . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12**  **2.9 Equipment Inspection/Maintenance . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13**  **2.10 Excavation/Trenching/Shoring . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13**  **2.11 Floor/Wall Openings . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14**  **2.12 Hearing Conservation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16**  **2.13 Housekeeping . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18**  **2.14 Manual Lifting . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 19**  **2.15 Mechanical Lifting . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 19**  **2.16 Mechanical and Electrical Safety . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 19**  **2.17 New Employee Orientation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 20**  **2.18 Power and Hand Tools . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 20**  **2.19 Process Safety Management . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 20**  **2.20 Scaffolding . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 21**  **2.21 Stairways and Ladders . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 22**  **2.22 Travel Safety . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 24**  **2.23 Thermal Stress . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 24**  **2.24 Welding and Cutting . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 26**  **2.26 Lockout/Tagout (LOTO) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 26**  **2.27 Fall Protection . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 27**  **2.28 Combustible Gas (LEL), Carbon Monoxide, Hydrogen Sulfide, and/or Ox ygen**  **Monitors . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 38**  **2.29 Emergency Response/Evacuation Program . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 41**  **2.30 Compressed Air Systems . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 42**  **2.31 Concrete Construction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 42**  **2.32 Powder-Actuated Tools . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 42** **Section Page** 

**3.0 Chemical Safety Guidelines . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 43**  **3.1 General Characteristics . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 45**  **3.2 Acids . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 47**  **3.3 Bases . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 47**  **3.4 Compressed Gases . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 48**  **3.5 Cryogenic Materials . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 50**  **3.6 Flammable Liquids and Gases . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 51**  **3.7 Organic Solvents . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 52**  **3.8 Oxidizing Agents . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 53**  **3.9 Asbestos Awareness . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 53**  **3.10 Benzene Awareness . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 54**  **3.11 Hydrogen Sulfide Awareness . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 54**  **3.12 Lead Awareness . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 56**  **4.0 Hazard Communication Requirements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 57**  **4.1 Material Safety Data Sheets . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 59**  **4.2 Chemical Labelling . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 60**  **4.3 Employee Exposure Monitoring . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 61**  **4.4 Employee Medical Surveillance . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 61**  **4.5 Employee Access to Records . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 61**  **5.0 Personal Protective Equipment . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 63**  **5.1 Respiratory Protection . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 63**  **5.2 Gloves . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 66**  **5.3 Protective Eyewear . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 66**  **5.4 Protective Clothing . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 67**  **5.5 OSHA Levels of Protection . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 68**  **5.5 Training for the Use Personal Protective Equipment . . . . . . . . . . . . . . . . . . . . . . 70** **DEECO Health and Safety Plan Page 1 January 2010**



### 1.0 Introduction **DEECO, Inc. (DEECO) is committed to the health and safety of its empl oyees. In order to ensure**  **that all tasks are performed safely, this Health and Safety Plan (HSP) has been prepared. The**  **procedures detailed in this HSP outline individual responsibilities, specific operating procedures,**  **training requirements, and specific information on potential safety and health ha zards.**  **The hazards faced by DEECO field personnel are varied, and speci fic controls of many hazards are**  **the responsibility of the client. This HSP will enable employees to rec ognize potential hazards so**  **that the client may take actions to correct the condition before t he work is performed. This HSP also**  **identifies DEECO activities which may pose significant health and safet y risks.**  1.1 Responsibilities **This section details the responsibilities for employees and ma nagement in the implementation of the**  **HSP.**

President **The President of DEECO has overall responsibility for compliance with all applicable federal and**  **state regulations and the provisions of this HSP. Periodic meeting s with managers and employees**  **should be conducted to discuss:**

# **The importance of health and safety.** # **Changes in regulations regarding health and safety.** # **Recent employee monitoring results.** # **Any recent employee accidents/injuries and possible preventive measures to avoid**  **a recurrence. In addition to the above responsibilities, the President is responsi**  **ble for authorizing any deviations from the HSP.**  Managers **Project managers and field team leaders are responsible fo r the health and safety of all persons**  **assigned to the specific project. Project managers and field team lea ders must ensure that:**  # **Employees are properly trained to perform all tasks in a safe manner.** # **Proper personal protective equipment are available and in good wor king condition.**  # **Persons using personal protective equipment have been instructed on their use.** # **Emergency equipment is available and in good working condition.** # **Employees are informed of any exposure monitoring performed in thei r work area**  **that may be representative of their chemical exposure.** # **All safety considerations have been discussed with the client prior to mobil ization.**  # **All aspects of the projects have been discussed and are underst ood with the team**  **leader and team members.** # **All appropriate safety equipment is available and in good working condition prior to**  **mobilization.** # **All records (employee training, respirator fit-testing, etc .) are present for all team** **DEECO Health and Safety Plan Page 2 January 2010 members.**  # **Copies of MSDSs for all chemicals used by DEECO are available for the c lient.**  # **All tasks are performed in a safe manner.** # **All accidents, injuries, or spills are reported immediately.** # **Any unsafe condition is reported immediately.** # **They cooperate with any monitoring surveys.** DEECO Safety Officer **The DEECO Safety Officer (SO) is responsible for the revi ew and maintenance of the Health &**  **Safety Plan. In addition, the SO is responsible for:** # **Identifying when employee exposure monitoring is necessary.** # **Writing exposure reports and reporting results to the appropria te department manager**  **and employees.** # **Ensuring that appropriate employee training is provided.** # **Investigating reported accidents with department managers.** # **Ensuring that new information on health, safety, employee training, or changes in**  **legal requirements are conveyed to the Director of Field Services.** 1.2 Employee Conduct **Appropriate employee conduct is essential in conveying a profess ional image to DEECO clients.**  **When performing work on client premises:** # **Dress professionally.** # **Contact the team leader if problems with a client arises.** # **Discuss disagreements with other DEECO personnel in private, not in front of the**  **client.** # **Do not discuss DEECO company policies or practices with client s (e.g. management,**  **compensation. etc.)** # **Direct all questions regarding sampling or project activities to the te am leader.**  # **Do not convey DEECO in a negative manner to clients. Any disagree ments with**  **company practices should be discussed directly with your manager.** # **Do not volunteer data to client employees.** # **Release data only to the designated client contact.** # **Do not promise a date for the final report. Have the client c ontact the project**  **manager or coordinator for a final report date.** # **Remain busy while on the client's premises.** # **Remain within designated areas of plant site.** # **Notify team leader when leaving area.** # **Notify client when leaving site for lunch or the end of the day.** # **Be on time for client meetings. If problems arise, call the client im mediately if the**  **scheduled time cannot be kept.** # **Follow all rules and regulations of the client while on the plant site.** # **If approached by the news media, do not offer any information. Refer all questions**  **to the client. DEECO Health and Safety Plan Page 3 January 2010** 

Drugs and Alcohol Use **It is DEECO's desire to provide a drug-free, healthful, and safe workplace. To promote this goal,**  **employees are required to report to work in appropriate mental and physical condition to perform**  **their jobs in a satisfactory manner. While on DEECO premises and while conducting business-related act**  **ivities off DEECO premises, no employee may use, possess, distribute, sell, or be under the infl**  **uence of alcohol or engage in the unlawful manufacture, distribution, dispensation, possession, or use of ill**  **egal drugs. Violations of this policy may lead to disciplinary action, up to and including i**  **mmediate termination of employment, and/or required participation in a substance abuse re**  **habilitation or treatment program. Such violations may also have legal consequences.**  **The legal use of prescribed drugs is permitted on the job only if it does not impair an employee's**  **ability to perform the essential functions of the job effecti vely and in a safe manner that does not**  **endanger other individuals in the workplace. To inform employees about important provisions of this policy, DEEC**  **O has established a drug-free awareness program. The program provides information on the dangers**  **and effects of substance abuse in the workplace, resources available to employees, and cons**  **equences for violations of this policy.**  **Employees with questions or concerns about substance dependency or ab use are encouraged to**  **discuss these matters with their supervisor or the Personnel Di rector to receive assistance or referrals**  **to appropriate resources in the community. Employees with drug or alcohol problems that have not resulted in, a**  **nd are not the immediate subject of, disciplinary action may request approval to take unpai**  **d time off to participate in a rehabilitation or treatment program through DEECO's health insur**  **ance benefit coverage. Leave may be granted if the employee agrees to abstain from use of the**  **problem substance; abides by all DEECO policies, rules, and prohibitions relating to conduct in the wor**  **kplace; and if granting the leave will not cause DEECO any undue hardship.**  **Under the Drug-Free Workplace Act, an employee who performs work f or a government contract**  **or grant must notify DEECO of a criminal conviction for drug- related activity occurring in the**  **workplace. The report must be made within five days of the conviction. Employees with questions on this policy or issues related to drug or**  **alcohol use in the workplace should raise their concerns with their supervisor or the Personnel D**  **irector without fear of reprisal.**

Abusive Language **Abusive or vulgar language, ethnic or sexual slurs and insults will not be tolerated on client or**  **DEECO premises. Use of such language is not only offensive, but may be seen as illegal**  **harassment. Inappropriate language or insults can result in imm ediate, appropriate action upon the**  **employee by DEECO. If problems with employee use of such l anguage occurs, notify your manager.** **DEECO Health and Safety Plan Page 4 January 2010**

1.3 Pre-Work Safety Considerations **The Project Coordinator or Manager should determine through a site visit, or through extensive**  **conversations with the client, if any unusual safety hazards exist at the work site. Additional**  **equipment, if needed, should be determined by the Project Coordinator/Ma nager and the DEECO**  **S.O.** 1.4 Employee Safety Education, Training, and Evaluation **All DEECO personnel shall initially receive the equivalent of t he OSHA 40-hour Training for**  **Hazardous Waste Operators. The 8-hour Refresher Training shall b e completed annually by all**  **personnel. Additional training and education may be required for specific jo**  **b responsibilities. The training requirements for additional education shall be set by the President.**  Employee Safety Evaluation Program **An annual evaluation of each employee’s safety performance will be conducted. Evaluating an employee’s safety performance involves measuring t**  **he level at which employees are achieving both their own personal safety goals and the company’s ex**  **pected safety performance standards. Integrating health and safety into a performance apprai**  **sal system provides management with a unique opportunity to tie the employee’s accountabilities a**  **nd achievements to the company’s objectives and strategic plans.**  **The goals of the Employee Safety Evaluation Program are; 1. Communicating information to employees on how well they are mee**  **ting the health and safety performance expectations of their jobs;**  **2. Identifying areas for coaching to help employees improve their health and safety performance**  **and develop safe work practices; 3. Providing opportunities to further communicate the organization’s**  **health and safety performance expectations;**  **4. Supporting the organizational succession plan; 5. Providing feedback to the organization about its recruitment and s**  **election process as well as its integrated health and safety training/development program;**  **6. Providing feedback about the employee’s perceptions of the compa ny’s health and safety**  **performance and standards. For employees, meeting the health and safety expectations of a job requires**  **them to: 1. Report hazards or hazardous conditions to their supervisor;** **DEECO Health and Safety Plan Page 5 January 2010**

**2. Work in a safe manner at all times by using appropriate pr otective gear and controls on**  **equipment; 3. Follow company policies and procedures;**  **4. Wear personal protective equipment as instructed; 5. Participate in health and safety initiatives (e.g. ergonomic a**  **ssessment, hygiene testing etc.) For supervisors, meeting the health and safety expectations of a job require**  **s the ability to: 1. Coach employees on safe work practices;**  **2. Enforce company policies and procedures; 3. Act as a positive role model for staff with respect to safe work practi**  **ces; 4. Support any staff who are members of the joint health and safety committee;**  **5. Be aware of their legal requirements under the Occupational Health and Safe ty Act;**  **6. Review new jobs/tasks/processes/equipment for safety concerns; 7. Follow-up on reported concerns in a timely fashion;**  **8. Encourage employee input into safety-related concerns and solution- finding processes; and**  **9. Discipline staff when required for failure to follow safety procedures. The Employee Safety Evaluation Program will quantify the health**  **and safety areas being monitored and provide qualitative feedback on employee health and safety performance.**  **The Employee Safety Evaluation Program will evaluate a employ ee’s performance on the following;**  **1. Reporting hazards or hazardous conditions to their supervisor; 2. Working in a safe manner at all times by using appropriate protecti**  **ve gear and controls on equipment;**  **3. Following company policies and procedures; 4. Wearing personal protective equipment as instructed;**  **5. Participating in health and safety initiatives (e.g. ergonomic assessment, hygiene testing etc.)**  **The Employee Safety Evaluation Program will evaluate a supervisor’s performance on the following;** **DEECO Health and Safety Plan Page 6 January 2010**

**1. Effectiveness in managing health and safety issues in their de partment or area of**  **responsibility; and 2. Establishing specific criteria for minimum health and safety standards** 

**. DEECO Health and Safety Plan Page 7 January 2010** 



### 2.0 General Safety Requirements **The procedures and guidelines detailed in the following sections are to be used by DEECO Field**  **personnel while performing work on either DEECO or client premis es. If the client has additional**  **safety procedures, field personnel are to follow the procedures whi ch are more stringent. In all cases,**  **all OSHA, MSHA and/or EPA requirements shall be met.** 2.1 First Aid for Accidents and Injuries **In the absence of an infirmary, clinic, hospital, or physician, that is reas onably accessible in terms**  **of time and distance to the worksite, which is available for the t reatment of injured employees, a**  **person who has a valid certificate in first-aid training from t he U.S. Bureau of Mines, the American**  **Red Cross, or equivalent training that can be verified by documentary evidence, s hall be available**  **at the worksite to render first aid. First aid supplies shall be easily accessible when require**  **d. The contents of the first aid kit shall be placed in a weatherproof container with individual sealed packages**  **for each type of item, and shall be checked by the employer before being sent out on each job a**  **nd at least weekly on each job to ensure that the expended items are replaced.**  **Proper equipment for prompt transportation of the injured pers on to a physician or hospital, or a**  **communication system for contacting necessary ambulance service, shall be provided.**  **In areas where 911 is not available, the telephone numbers of the phy sicians, hospitals, or**  **ambulances shall be conspicuously posted. Where the eyes or body of any person may be exposed to injurious c**  **orrosive materials, suitable facilities for quick drenching or flushing of the eyes and body (e.g. safety showers a**  **nd emergency eyewash systems) shall be provided within the work area for im**  **mediate emergency use. The location of these facilities for quick drenching or flushing of the eyes**  **and body shall be identified and all employees in the affected area will be shown the location of these faci**  **lities. The reporting of any work-related accident, illness, or injury is**  **required by Worker's Compensation regulations. North Carolina law requires that a manager's repor**  **t on an accident or injury be filed within 10 days after the incident.**  **The reporting of incidents will enable employees and management to determine what possible**  **corrective actions can be taken to avoid a recurrence of the incident. Responsibilities**  **Project managers or coordinators must ensure that:** # **Immediate care is obtained for all accidents or injuries.** # **All employee accidents or injuries are recorded on the DEECO A ccident Report form**  **by the employee.** # **Copies of the Accident Report form are sent to the Personnel Director and the**  **DEECO S.O. DEECO Health and Safety Plan Page 8 January 2010** 

# **Accident reports are reviewed with the employee and possible p reventive measures**  **are noted and implemented if required.** # **Any equipment involved in an incident is removed from service until re paired or**  **replaced. The Personnel Director must ensure that:**  # **Necessary North Carolina forms are completed, distributed, and ma intained for any**  **occupational injury or accident.** # **The OSHA Form 300 is updated and posted on the bulletin board in the Br eak Room.**  **Employees must ensure that:** # **All accidents or injuries are reported immediately to the D epartment Manager,**  **Project Manager, or Project Coordinator.** # **All details of the accident or injury are recorded on the DEECO Accident Report**  **form.** 2.2 Audit/Inspection Procedures **Safety audits and inspections of all work areas will be conducted periodically by the Safety Officer**  **or a representative thereof. Procedures for conducting an inspection of a job site will be as follows.**  **The following items, while not inclusive, are indicators of some of t he areas of concern for good job**  **site safety covered in a routine inspection or audit. Item**  **Acceptable Not Acceptable**  **NA Employee Safety Training ( ) ( ) ( )**  **Safety Manual On site ( ) ( ) ( ) Assigned Responsibilities ( ) ( ) ( )**  **Confined Space Entry ( ) ( ) ( ) Fire Protection ( ) ( ) ( )**  **Electrical - GFCI or Grounding Program ( ) ( ) ( ) Equipment Inspection/Maintenance ( ) ( ) ( )**  **Excavation/Trenching/Shoring ( ) ( ) ( ) Floor/Wall openings ( ) ( ) ( )**  **Hearing Conservation ( ) ( ) ( ) Housekeeping ( ) ( ) ( )**  **Mechanical Lifting ( ) ( ) ( ) Mechanical and Electrical Safety ( ) ( ) ( )**  **Power Tools ( ) ( ) ( )**  **Scaffolding ( ) ( ) ( )**  **Stairways and Ladders ( ) ( ) ( ) Travel Safety Followed ( ) ( ) ( )**  **Thermal Stress ( ) ( ) ( ) Chemical Safety Guidelines Met ( ) ( ) ( )**  **Hazard Communication Requirements Met ( ) ( ) ( ) Material Safety Data Sheets On site ( ) ( ) ( )**  **Chemical Labelling Clear and correct ( ) ( ) ( ) Personal Protective Equipment ( ) ( ) ( )** **DEECO Health and Safety Plan Page 9 January 2010**

**Respiratory Protection ( ) ( ) ( ) Gloves**  **( ) ( ) ( ) Protective Eyewear ( ) ( ) ( )**  **Protective Clothing ( ) ( ) ( ) Fall Protection ( ) ( ) ( )**  2.3 Bloodborne Pathogens **In the normal course of work, it is not reasonably anticipated that DEECO employees will encounter**  **occupational exposure of the skin, eye, mucous membrane, or parentera l contact with blood or other**  **potentially infectious materials. Consequently, DEECO is not requi red to have a written Exposure**  **Control Plan. However, in the case of an accident, all contact with blood or blood pr**  **oducts should be avoided to prevent the risk of exposure to bloodborne pathogens, . Cuts, scrap**  **es, and abrasions should be reported to the safety officer or appointed representative and pr**  **oper health care should be provided by trained personnel. Rubber gloves should be worn at all times w**  **hen treating injuries causing risk to bloodborne pathogens.**  **Rubber gloves, protective resuscitation masks, and other first aid items are contained in the field first**  **aid kit which is to be present on each project.** 2.4 Aerial Devices (Man Lifts) **On occasions, DEECO employees may be required to use aerial devices (man lifts) to access**  **sampling locations. The following are examples of aerial devices; 1. An aerial device is any vehicle-mounted device, telescoping or ar**  **ticulating, or both, which is used to position personnel;**  **2. An aerial ladder is an aerial device consisting of a single - or multiple-section extensible**  **ladder; 3. An articulating boom platform is an aerial device with two or**  **more hinged boom sections.; 4. An extensible boom platform is an aerial device (except la**  **dders) with a telescopic or extensible boom. Telescopic derricks with personnel platform a**  **ttachments shall be considered to be extensible boom platforms when used with a personnel plat**  **form; 5. An insulated aerial device is an aerial device designed for wor**  **k on energized lines and apparatus;**  **5. A mobile unit is a combination of an aerial device, its vehicle, and related equipm ent;**  **6. A platform is any personnel-carrying device (basket or bucket) which is a component of an**  **aerial device; 7. A vehicle is any carrier that is not manually propelled; and** **DEECO Health and Safety Plan Page 10 January 2010**

**8. A vertical tower is an aerial device designed to elevate a p latform in a substantially vertical**  **axis.** Specifc Requirements for Aerial Lifts **Only trained persons shall operate an aerial lift. For ladder trucks and tower trucks, before the truck is moved for highwa**  **y travel, aerial ladders will be secured in the lower traveling position by the locking device ab**  **ove the truck cab, and the manually operated device at the base of the ladder, or by other e**  **qually effective means (e.g., cradles which prevent rotation of the ladder in combination with positive acting linear ac**  **tuators). For extensible and articulating boom platforms, the lift controls**  **shall be tested each day prior to use to determine that such controls are in safe working condition.**  **Belting off to an adjacent pole, structure, or equipment while worki ng from an aerial lift shall not**  **be permitted. Employees shall always stand firmly on the floor of the basket,**  **and shall not sit or climb on the edge of the basket or use planks, ladders, or other devices for a work position.**  **A body belt shall be worn and a lanyard attached to the boom or bas ket when working from an aerial**  **lift. Boom and basket load limits specified by the manufacturer shall not be exce**  **eded. The brakes shall be set and outriggers, when used, shall be positi**  **oned on pads or a solid surface. Wheel chocks shall be installed before using an aerial lift on an incline.**  **An aerial lift truck may not be moved when the boom is elevated in a working position with men in**  **the basket, except for equipment which is specifically desig ned for this type of operation in**  **accordance with the provisions of OSHA 1910.67, paragraphs (b)(1) and (b)(2). Articulating boom and extensible boom platforms, primarily desi**  **gned as personnel carriers, shall have both platform (upper) and lower controls. Upper controls shall**  **be in or beside the platform within easy reach of the operator. Lower controls shall provide for**  **overriding the upper controls. Controls shall be plainly marked as to their function. Lower level**  **controls shall not be operated unless permission has been obtained from the employee in the lift, except i**  **n case of emergency. Climbers shall not be worn while performing work from an aerial lift.**  **The insulated portion of an aerial lift shall not be altered i n any manner that might reduce its**  **insulating value. Before moving an aerial lift for travel, the boom(s) shall be i**  **nspected to see that it is properly cradled and outriggers are in stowed position, except as provided in OSHA 1910.67,**  **paragraph (c)(2)(viii). DEECO Health and Safety Plan Page 11 January 2010** 

2.5 Confined Space Entry **A Confined Space in an enclosure having limited access and egress. Examples of confined spaces**  **include, but are not limited to:** # **Storage tanks, tank cars, process vessels, bins, silos, boiler s, and other tank-like**  **compartments usually with only a manhole for entry.** # **Open-topped spaces of more than 4 feet in depth, such as pits, vault s and vessels, not**  **subject to good natural ventilation.** # **Septic tanks, sewers, underground utility tunnels, pipelines, and similar struct ures.**  **Confined spaces may contain atmospheres that are hazardous to lif e and health because of the**  **presence of flammable, explosive, or toxic contaminants or becaus e of either a deficiency or excess**  **of oxygen. It is DEECO policy not to permit employees to ente r a confined space. In the event that**  **confined space entry is necessary as part of a project, the client is to provide DEECO personnel with**  **training, life-support equipment, and emergency/rescue personnel duri ng any confined space work.**  2.6 Documented Safety Meetings **Safety Meetings will be held on the first day of a project, on-site. A review of safety conditions will**  **be made by the project manager/field team leader at the end of each day's work. Any unusual or**  **notable health or safety concerns will be noted in the field log, and discussed with all field team**  **members. All field safety meetings will be documented in the field log book, and a copy of the**  **appropriate pages will be included in the final written report to the cli ent.**  **The President shall ensure that meetings are held periodically to address safety violations,**  **procedures, and/or updates. The dates, attendees, and topics of these meetings will be documented**  **and placed in the Safety Meetings file.**

2.7 Fire Protection **Every employee should be aware of the combustible characterist ics of the chemicals and materials**  **they use or may come in contact with. This information can be found on the chemical's Material**  **Safety Data Sheet (MSDS), or labels on the material container. When performing work on a client's site, the Project Manager or Coordinator must:**  # **Be able to clearly identify all regular and emergency ex its in the building or work**  **area.** # **Receive a site evacuation route from the client.** # **Receive emergency notification procedures from the client (e .g. number to call in**  **case of fire, explosion, etc.).** # **Ensure all team members are aware of the above information. Care should be taken when storing or using chemicals or hazardous materials in DE**  **ECO vehicles or mobile laboratories. All vehicles and mobile laboratories are equipped w**  **ith fire extinguisher. If a fire should occur:**  # **Aim fire extinguisher at the base of the fire.** # **Never allow the fire to come between you and an exit.** # **Never use water on electrical or burning liquid fires. If the fire is too large to be contained with one fire extinguisher:** **DEECO Health and Safety Plan Page 12 January 2010**

# **Immediately notify the site emergency contact. Report locat ion of fire, material**  **burning, and if any injuries are involved.** # **Evacuate the area.** Fire Extinguisher Classes
Class A **- for use on ordinary combustible materials such as paper, wood, etc.** Class B **- for use on flammable and combustible liquids, greases, paints, etc.** Class C **- for use on electrical fires.** Class D **- for use on combustible metals. All fire extinguishers located in the DEECO vehicles and mobil**  **e laboratories are rated for Class A, B, and C fires.**  2.8 Electrical - GFCI or Grounding Program **It is the policy of DEECO to establish and implement an assur ed equipment grounding conductor**  **program on work sites covering all cord sets, receptacles whic h are not a part of the permanent**  **wiring of the building or structure, and equipment connected by cord and p lug which are available**  **for use or used by employees. This policy shall apply to all w ork sites not equipped with ground**  **fault circuit interrupters in accordance with OSHA standard 1926.400 (h). The project manager/field team leader shall implement the**  **assured equipment grounding conductor program where existing and predictable hazards are identifyedi**  **the surrounding area or working conditions which are unsanitary, hazardous or dangerous to employees, and**  **who is authorized to take prompt corrective measures to eliminate them.**  **The project manager/field team leader shall be responsible and account able for the following:**  **Each cord set, attachment cap, plug and receptacle of cord set a nd any equipment connected by cord**  **and plug, except cord sets and receptacles which are fixed and not exposed to damage, shall be**  **visually inspected before each day's use for external defects, such as def ormed or missing pins, or**  **insulation damage, and for indication of possible internal damage . Equipment found damaged or**  **defective may not be used until repaired. The project manager/field team leader is responsible for t**  **ests on all cord sets, receptacles which are not a part of the permanent wiring of the building or structure, a**  **nd cord and plug connected equipment repaired to be grounded. Tests shall be documented on the**  **log for assured equipment grounding conductor program and shall be on the job site for inspection**  **by OSHA officials and any affected employee. Equipment that does not meet prescribed tes**  **t shall not be put into service. The following tests shall be performed:**  **1. All equipment grounding conductors shall be tested for continuity and shall be ele ctrically**  **continuous. DEECO Health and Safety Plan Page 13 January 2010** 

**2. Each receptacle and attachment cap or plug shall be tested for correct attachment of the**  **equipment grounding conductor. The equipment grounding shall be connected to it s**  **terminal.. In accordance with OSHA Construction Safety and health Standards 1926.21 Safety**  **Training and Education, project manager/field team leader shall attend such**  **training sessions as the company may deem necessary.**  **A copy of this policy shall be at the job site for inspec tion and copy by OSHA officials and any**  **affected employee. Management retains the authority to designa te that certain jobs comply with**  **regulation 1926.400 (h) by use of ground fault circuit interrupters in li eu of the program established**  **above. A copy of the completed forms will be kept on each appli cable job site for inspection**  **purposes. Electric power operated tools and power cords shall be UL appr**  **oved, double insulated or have the third wire ground whole and in place. All 120-volt single phase, 15- and 20**  **-ampere receptacle outlets on construction sites, which are not a part of the permanent**  **wiring of the building or structure and which are in use by employees, shall have approved ground-fault cir**  **cuit interrupters (GFCI) for personnel protection.**  **All equipment and power cords are to be inspected prior to the fi eld project. Any equipment or**  **power cord which is not in proper working order shall be tagged as "D AMAGED-DO NOT USE"**  **and returned to the DEECO laboratory for repair or replacement.** 2.9 Equipment Inspection/Maintenance **Mechanical and electrical equipment will be periodically insp ected according to the manufacturers**  **instructions to ensure they are in proper working order, all cords and parts are not chipped, frayed**  **or broken, and recommended maintenance procedures are conducted on schedule. E quipment that**  **does not meet safety standards will be repaired or replaced before use.** 2.10 Excavation/Trenching/Shoring **DEECO personnel shall not perform excavation or trenching work, nor sha ll DEECO personnel be**  **expected to enter an excavation or trench. Should such entry be requir ed on a project, the client must**  **ensure: - Underground lines, equipment and electrical cables shall be located, identif**  **ied and de-energized prior to beginning work.**  **- Walls and faces of trenches and excavations, four or more feet de ep, are shored,**  **sloped or shielded as dictated by the type of soil encountered. - Daily inspections are conducted by a competent person for evidenc**  **e of a situation that could result in possible cave-ins, indications of failure of pr**  **otective systems or other hazardous conditions.**  **- Employees are not be permitted underneath loads handled by lifting or digging**  **equipment. Employees shall be required to stand away from any vehi cle being**  **loaded or unloaded. DEECO Health and Safety Plan Page 14 January 2010** 

**- Employees are be protected from excavated or other material s and equipment that**  **could pose a hazard by falling or rolling in excavations. - Physical barriers are be placed around or over trenches and ex**  **cavations. Barriers**

**shall be removed only when necessary to provide access to personnel or equipment.**  **Flashing light barricades shall be provided at night. - A stairway, ladder, ramp or other safe means of egress**  **is located in trench excavations that are four feet or more in depth so as to require no**  **more than 25 feet of lateral travel for employees.**  **- Backfilling and removal of support systems are performed only a fter employees have**  **cleared the area. All excavations shall be backfilled and graded promptl y.**  **- Trenches greater than four feet deep shall require an approved conf ined space entry**  **permit. The client requiring DEECO personnel to enter a trench or exc**  **avation shall provide training to DEECO personnel in accordance to client and OSHA regulations and policies.**  2.11 Floor/Wall Openings **With regards to guarding floor and wall openings and holes, workers wi ll comply with 29 CFR**  **1910.23 and 1926, Subpart M. General requirements are as follows:**  **1. Ladderway floor openings shall be guarded by a standard railing and toe-boards or cover.**  **In general, the railing shall be provided on all exposed sides, exc ept at entrances to stairways.**  **2. Hatchways and chute floor openings shall be guarded by one of the following: a. Hinged covers and a standard railing with only exposed side.**  **b. A removable standard railing with toe-board on not more than two sides and fixed**  **standard railings with toe boards on all other exposed sides. 3. Temporary floor openings, into which persons can accidentally wal**  **k, shall be guarded by either a standard railing with toe-board on all exposed sides, or a**  **floor hole cover that is secured against accidental displacement.**  **4. Wall openings, from which there is a drop of more than four feet , and the bottom of the**  **opening is less than three feet above the working surface, shall be guarded as fol lows:**  **a. A standard rail, if that will effectively reduce the danger of falling. If the bottom of**  **a wall opening is less than four inches above the working surface, a toe-board or an**  **enclosing screen shall also be provided. 5. Every open-sided floor or platform four feet or more above adjac**  **ent floor or ground level shall be guarded by a standard railing or equivalent. A toe-board s**  **hall be provided wherever, beneath the open sides, persons can pass or there is moving machine**  **ry or there is equipment with which falling material could create a hazard.** **DEECO Health and Safety Plan Page 15 January 2010**

**Standard Specifications 1. A standard railing shall consist of top rail, intermediate rail, toe-boa**  **rd and posts, and shall have a vertical height of approximately 42 inches.**  **a. The intermediate rail shall be halfway between the top r ail and the floor, platform**  **runway or ramp. b. Posts shall be spaced not more than eight feet on corners.**  **c. A completed railing structure shall be capable of withsta nding a load of at least 200**  **pounds applied in any direction at any point on the top rail, wit h a minimum of**  **deflection. 2. A standard handrail shall be of a construction similar to a st**  **andard rail except that it is mounted on a wall or partition and does not include an intermediate rail.**  **a. The height to handrails shall not be more than 34 inches or less tha n 30 inches from**  **top surface to tread or ramp. b. Handrails and railings shall be provided with a clearance of a**  **pproximately three inches between the rail and any other object.**  **3. Floor opening covers shall be of any material that meets the following strength requirements:**  **a. The cover, when located in roadways or vehicular aisles, shall be designed to c arry**  **a truck rear axle load of at least two times the maximum intended load. b. The floor opening cover shall be capable of supporting the max**  **imum intended load and so installed as to prevent accidental displacement.**  **4. Wall opening protection shall meet the following requirements: a. Barriers shall be of such construction and mounting that, when in pla**  **ce, they are capable of withstanding a load of at least 200 pounds applied in any di**  **rection (except upward) with a minimum deflection.**  **5. During the performance of work on low pitched roofs, employees shall be protected at all**  **open sides and edges by the use of a motion-stopping safety system. Barricades**  **1. Signs, signals and barricades shall be posted to detour passage of persons and vehicles at**  **locations where potential hazards exist. a. Barricades must be 42 inches high.**  **b. Barricades should be kept four feet back from the edge of ex cavations, holes, and**  **platforms and six feet back from the edge of low-pitched roofs. c. Barricades with flashing lights shall be provided at night.** **DEECO Health and Safety Plan Page 16 January 2010**

**2. All employees engaged in built-up roofing work will undergo traini ng so that they are able**  **to recognize and deal with the hazards of falling associated the w orking near a roof**  **perimeter.** 2.12 Hearing Conservation **DEECO personnel may be exposed to excessive noise levels while on a client's premises. The**  **project manager/field team leader will ensure all high noise areas have been identified, and that each**  **member of the field team is aware of the location of these ar eas. Hearing protection is to be provided**  **by DEECO to field personnel at no cost. Employees will wear hearing protection as instructed and**  **in all areas required.** Hearing Conservation Training Program **DEECO will train each employee who is exposed to noise at or a bove an 8-hour time weighted**  **average of 85 decibels. DEECO will institute a training progr am and ensure employee participation**  **in the program. The training program will be repeated annually for each empl**  **oyee included in the hearing conservation program. Information provided in the training program will**  **be updated to be consistent with changes in protective equipment and work processes.**  **DEECO will ensure that each employee is informed of the effec ts of noise on hearing, the purpose**  **of hearing protectors, the advantages, disadvantages, and attenuation of various types, and**  **instructions on selection, fitting, use, and care, and the purpose of audiom etric testing and an**  **explanation of the audiometric test procedures. DEECO will provide annual audiometric exams for all personnel. T**  **he President is responsible for ensuring compliance with applicable regulations (29 CFR 1910.95, "O**  **ccupational Noise Exposure", and 1926.101, "Hearing Protection").**  Audiometric Testing Program **DEECO will establish and maintain an audiometric testing progr am by making audiometric testing**  **available to all employees whose exposures equal or exceed an 8- hour time-weighted average of 85**  **decibels. The program shall be provided at no cost to employees. Audiometric tests will be be performed by a licensed or ce**  **rtified audiologist, otolaryngologist, or other physician, or by a technician who is certified by the Council**  **of Accreditation in Occupational Hearing Conservation, or who has satisfactorily demonstrated compet**  **ence in administering audiometric examinations, obtaining valid audiograms, and properly u**  **sing, maintaining and checking calibration and proper functioning of the audiometers be**  **ing used. A technician who operates microprocessor audiometers does not need to be certifi**  **ed. A technician who performs audiometric tests must be responsible to an audiologist, otolaryngologist or p**  **hysician. All audiograms obtained pursuant to this section shall meet the r**  **equirements of OSHA 1910, Appendix C: "Audiometric Measuring Instruments."** **DEECO Health and Safety Plan Page 17 January 2010**

Baseline Audiogram **Within 6 months of an employee's first exposure at or above the ac tion level, DEECO will establish**  **a valid baseline audiogram against which subsequent audiograms can be compar ed.**  **Where baseline audiograms are obtained more than 6 months after t he employee's first exposure at**  **or above the action level, employees shall wear hearing prote ctors for any period exceeding six**  **months after first exposure until the baseline audiogram is obtained. Testing to establish a baseline audiogram shall be preceded**  **by at least 14 hours without exposure to workplace noise. Hearing protectors may be used as a subst**  **itute for the requirement that baseline audiograms be preceded by 14 hours without exposure to workplace noi**  **se. DEECO will notify employees of the need to avoid high levels of non-occupational noise exp**  **osure during the 14-hour period immediately preceding the audiometric examination.**  Annual Audiogram **At least annually after obtaining the baseline audiogram, DEEC O will obtain a new audiogram for**  **each employee exposed at or above an 8-hour time-weighted average of 85 decibels.** Evaluation of Audiogram **Each employee's annual audiogram will be compared to that empl oyee's baseline audiogram to**  **determine if the audiogram is valid and if a standard threshold shift (as defined in OSHA**  **1910.95(g)(10)) has occurred. This comparison may be done by a technician. If the annual audiogram shows that an employee has suffered a standa**  **rd threshold shift, DEECO will obtain a retest within 30 days and consider the results of the retest as the annual audi**  **ogram. An audiologist, an otolaryngologist, or a physician will review prob**  **lem audiograms and will determine whether there is a need for further evaluation. DEECO**  **will provide to the person performing this evaluation, a copy of the requirements for hearing**  **conservation as set forth in OSHA 1910.95 paragraphs (c) through (n), the baseline audiogram and most rece**  **nt audiogram of the employee to be evaluated, measurements of background sound pressure le**  **vels in the audiometric test room as required in OSHA 1910Appendix D: Audiometric Test Rooms, and rec**  **ords of audiometer calibrations required by OSHA 1910 paragraph (h)(5).**  Follow-up Procedures **If a comparison of the annual audiogram to the baseline audiogram i ndicates a standard threshold**  **shift, the employee will be informed of this fact in writing, within 21 days of the de termination.**  **Unless a physician determines that the standard threshold shift is not work related or aggravated by**  **occupational noise exposure, DEECO will ensure that the employees not us ing hearing protectors**  **will be fitted with hearing protectors, trained in their use a nd care, and required to use them.**  **Employees already using hearing protectors shall be refitted and retrained in the use of hearing**  **protectors and provided with hearing protectors offering greater attenuati on if necessary.** **DEECO Health and Safety Plan Page 18 January 2010**

**The employee will be referred for a clinical audiological eva luation or an otological examination,**  **as appropriate, if additional testing is necessary or if DEEC O suspects that a medical pathology of**  **the ear is caused or aggravated by the wearing of hearing protectors. The employee will be informed of the need for an otological exami**  **nation if a medical pathology of the ear that is unrelated to the use of hearing protectors is suspected.**  **If subsequent audiometric testing of an employee whose exposu re to noise is less than an 8-hour**  **TWA of 90 decibels indicates that a standard threshold shift is not p ersistent, DEECO will inform**  **the employee of the new audiometric interpretation and mMay disc ontinue the required use of**  **hearing protectors for that employee.**

Revised Baseline **An annual audiogram may be substituted for the baseline audiogram when, in the judg ment of the**  **audiologist, otolaryngologist or physician who is evaluating the audiog ram, that the standard**  **threshold shift revealed by the audiogram is persistent or the hea ring threshold shown in the annual**  **audiogram indicates significant improvement over the baseline audiogram.** 2.13 Housekeeping **Employees shall maintain a high standard of housekeeping on the job a t all times as an integral part**  **of the work The purpose of this requirement is to ensure the safet y of all personnel entering the lob**  **location and to maintain a condition of housekeeping that is consistent wi th the desired appearance**  **of a DEECO job location. Project managers/field team leaders shall clean up work ar**  **eas daily, store all equipment and construction materials in an orderly manner in storage areas. Ba**  **rricades shall be used for temporary storage of equipment and construction materials. All scrap construction mat**  **erials and waste shall be picked up and disposed of at least daily. All location procedur**  **es for waste disposal shall be followed. Form wood and other lumber shall be neatly stored when not**  **in use. All nails shall be removed or bent over to prevent puncture wounds.**  **All stairways, walkways, ladder cages and scaffolds shall be kept clear of all cords, cables, hosed,**  **materials and anything else that might hinder personnel access. Cords, cables and hosed at stairways,**  **walkways and scaffolds will be supported at least seven fee t overhead or laid flat outside of**  **walkways. All spills of oil, solvents, chemicals and any regulated liquids sh**  **all be reported to the site representative immediately and shall be properly cleaned up**  **and disposed of. Dumping of these materials in floor drains, sanitary sewers, storm sewers. drai**  **nage ditches, or other open ground is forbidden.**  **Employees shall be responsible for keeping all location roads f ree from all debris resulting from their**  **performance of the work. Storage of combustible and flammable m aterials shall not be located under**  **overhead pipelines and utilities. Loose materials on roofs or other overhead structures shall be**  **removed or secured to prevent being blown or bumped off. Accumulation of materials that may** **DEECO Health and Safety Plan Page 19 January 2010**

**create a fire hazard shall not be permitted. Storage of mat erials shall be at least eight feet from the**  **center of railroad tracks. Project managers/field team leaders shall perform a housekee**  **ping review of the work site at the end of each day. All concerns noted will be corrected prior to the field team leaving**  **the site.** 2.14 Manual Lifting **When lifting heavy objects, an improper lifting technique may re sult in a serious injury. When**  **lifting objects, ensure that you:** # **Know your limitation. Enlist help before lifting objects that are beyond your**  **strength.** # **Have cleared a path to carry the object, before lifting the object.** # **Lift with your legs, keeping your back straight.** # **Have a firm grip and a sure footing before lifting the object.** # **Lift objects gradually. Avoid jerking motions and awkward positions.** # **Avoid twisting your body when carrying the object. Turn your entire b ody with the**  **object.** 2.15 Mechanical Lifting **Mechanical lifting aids, such as hoists, trucks, dollies, and jacks ar e to be used to assist Field**  **personnel in handling heavy objects. Field personnel must ensure that:**

# **The rated capacity of the mechanical device is not exceeded.** # **When lifting objects to a higher work location, the area below the lifted object is kept**  **clear by restricting access using ropes, barricades, or other barr iers.**  # **Loads are not left suspended in the air. Raise the load only when it can be unloaded**  **at its destination.** # **Attempts are not made to catch or grab falling objects.** 2.16 Mechanical and Electrical Safety **Analytical Equipment The use and repair of analytical equipment can present unusual electri**  **cal and mechanical hazards. Before performing work on any piece of equipment:** 

# **Ensure that power has been disconnected from the unit.** # **Ensure that any reserve power (capacitors, batteries) are de-energized before working**  **on unit.** # **Do not remove any piece of equipment labelled "Trained Service Personnel Only"**

**. Call the appropriate service organization for repair of the unit.**  **Additional mechanical and electrical hazards may exist. Employ ees must be aware of all hazards**  **before performing any repair work. Employees should consult the cl ient's representative before**  **connecting transformers or other electrical lines to power suppl ies. See Lockout/Tagout procedures**  **in the Supplement of this manual. DEECO Health and Safety Plan Page 20 January 2010** 

2.17 New Employee Orientation **All new employees will undergo initial safety training which i ncludes assigned responsibilities, first**  **aid procedures (including bloodborne pathogens procedures), accident res ponse and reporting**  **procedures, emergency action plan and spill procedures, fire pr otection, general safety rules, and**  **housekeeping. Subsequent safety training will be provided based on job descr iption.** 

2.18 Power and Hand Tools **Improper use of power and hand tools can lead to serious injuries. Field personnel should be familiar**  **with the tools used and their operating manuals. Field personnel should ensure that:**

# **Tools are used for the propose for which they were designed.** # **Power tools must be either grounded or double-insulated.** # **Defective or damaged tools must be labelled and stored such that ot her employees**  **will not mistakenly use the tool.** # **Safety glasses with side shields or goggles must be worn when using power tools that**  **may produce projectiles.** 2.19 Process Safety Management **Many client locations will be required to provide DEECO (the cont ract employee) with process**  **safety management (PSM) information. The processes that requi re PSMs involves a flammable**  **liquid or gas (as defined in OSHA 1926.59(c)) on site in one location, in a quantity of 10,000 pounds**  **(4535.9 kg) or more except for hydrocarbon fuels used solely for workpla ce consumption as a fuel**  **(e.g., propane used for comfort heating, gasoline for vehicle refueling), if suc h fuels are not a part**  **of a process containing another highly hazardous chemical covered by t his standard and flammable**  **liquids stored in atmospheric tanks or transferred which are kept below their normal boiling point**  **without benefit of chilling or refrigeration. PSM describes th e procedures for preventing or**  **minimizing the consequences of catastrophic releases of toxic, r eactive, flammable, or explosive**  **chemicals. These releases may result in toxic, fire or explosion hazards The DEECO project manager/field team leader shall ensure t**  **hat all DEECO employees understand and follow these procedures.**  Management of Change **DEECO work activities at client’s facility may impact on the operation of a PSM regulated process.**  **The DEECO project manager/field team leader and the client’ s facility representative will perform**  **an initial process hazard analysis (hazard evaluation) on process es covered. The process hazard**  **analysis shall be appropriate to the complexity of the proce ss and shall identify, evaluate, and control**  **the hazards involved in the process as they relate to DEECO’s wor k activities. The client’s facility**  **representative shall determine and document the priority order for conducting process hazard**  **analyses based on a rationale which includes such considerations as extent of the process hazards,**  **number of potentially affected employees, age of the process, a nd operating history of the process.**  **The process hazard analysis must be conducted before any work by DEECO is c onducted.** **DEECO Health and Safety Plan Page 21 January 2010**

2.20 Scaffolding Scaffold Erection and Inspection **It is DEECO’s policy** not to **erect scaffolding. Scaffolding is typically the responsibi lity of the**  **client. Scaffolds shall be designed by a qualified person and s hall be constructed and loaded in**  **accordance with that design. Scaffolds shall be erected, moved, dismantled, or alt ered only under**  **the supervision and direction of a competent person qualified in scaf fold erection, moving,**  **dismantling or alteration. Such activities shall be performed only by experienced and trained**  **employees selected for such work by the competent person. Each day before using any scaffolding, ensure that the scaffolding ha**  **s been inspected by a person qualified in scaffold inspection.**  General Requirements for Scaffolding Use **1. The footing or anchorage for scaffolds shall be sound, rigid and c apable of carrying the**  **maximum intended load without settling or displacement. 2. Guardrails and toe-boards shall be installed on all open sides a**  **nd ends of scaffold platforms more than four feet above the ground or floor.**  **3. Scaffolds shall be provided with an access ladder or equivalent safe access**

**. 4. Employees shall not climb or work from scaffold handrails, mid-rails or brac**  **e members. 5. When free-standing manually propelled mobile scaffolds are u**  **sed, the height shall not exceed four times the minimum base dimension.**  **a.Employees shall not ride on mobile scaffolds when they are being moved. 6. All scaffolds shall be inspected by a competent person prior** **to use and shall be acceptance tagged.**  **7. Employees who erect scaffolds shall be trained in the proper means of b uilding scaffolds.**  **8. Employees using scaffolds shall be trained in the safe use of scaffolds. The project manager/field team leader must ensure that all**  **scaffolding is erected in accordance with OSHA regulations and the items listed above.**  **The project manager/field team leader must check with client 's representative to see if additional fall**  **protection is required when working on scaffolding.** Scaffold Use Training **DEECO shall have each employee who performs work while on a sc affold trained by a person**  **qualified in the subject matter to recognize the hazards associa ted with the type of scaffold being**  **used and to understand the procedures to control or minimize those hazards . The training shall**  **include the following areas, as applicable: 1. The nature of any electrical hazards, fall hazards and falling**  **object hazards in the work area; 2. The correct procedures for dealing with electrical hazards and**  **for erecting, maintaining, and disassembling the fall protection systems and falling object**  **protection systems being used; DEECO Health and Safety Plan Page 22 January 2010** 

**3. The proper use of the scaffold, and the proper handling of materials on the scaf fold; and**  **4. The maximum intended load and the load-carrying capacities of the scaffolds used. Additional training will be provided when changes in the types of sc**  **affolds, fall protection, falling object protection, or other equipment present a hazard about which an**  **employee has not been previously trained or when inadequacies in an affected employee's w**  **ork involving scaffolds indicate that the employee has not retained the requisite proficiency.**  2.21 Stairways and Ladders **With regards to stairways and ladders, employees should follow 29 C FR 1910.25, 26, and 27,**  **"Portable Wood Ladders, "Portable Metal Ladders, and Fixed Ladders" , and 1926 Subpart X,**  **"Stairways and Ladders". General Requirements**  **1. A stairway or ladder shall be provided at all personnel points of access where there is a break**  **in elevation of 19 inches or more, and no ramp, runway, sloped embankment or p ersonnel**  **hoist is provided. 2. A double-cleated ladder or two or more separate ladders shall**  **be provided when ladders are the only means of access or egress from a working area for 25 or**  **more employees, or when the ladder is to serve simultaneous two-way traffic.**  **3. When a building or structure has only one point of access between l evels, that point of access**  **shall be kept clear to permit free passage of employees. Stairways**  **1. Stairways that will not be a permanent part of the structur e on which construction work is**  **being performed shall have landings of not less than 30 inches in the di rection of travel and**  **extend at least 22 inches in width at every 12 feet or less of vertical rise. 2. Riser height and tread depth shall be uniform within each flight of stairs.**  **3. Where doors or gates open directly on a stairway, a platform shall be provided, and the swing**  **of the door shall not reduce the effective width of the platform to less than 20 inches. 4. Slippery conditions on stairways shall be eliminated before the sta**  **irways are used to reach other levels.**  **5. Except during stairway construction, foot traffic shall be prohi bited on skeleton metal stairs**  **where the treads and landings are to be filled in at a later da te, unless the stairs are fitted with**  **secured temporary treads and landings long enough to cover the entire t read and landing area.**  **6. Stairways having four or more risers or rising more than 30 inches , whichever is less, shall**  **be equipped with at least one handrail and one system along each unpr otected side or edge.**  **7. Stairrails shall be not less than 36 inches from the upper surf ace of the strairrail system to the**  **surface of the tread. 8. Mid-rails, screens, mesh, intermediate vertical me**  **mbers, or equivalent intermediate structural members, shall be provided between the top rail of the stair**  **rail system and the stair\way steps.** **DEECO Health and Safety Plan Page 23 January 2010**

**9. Handrails and the top rails of stairrail systems shall be capable of withstanding a force of at**  **least 200 pounds applied within two inches of the top edge, in any dow nward or outward**  **direction, at any point along the top edge. 10. Fixed stairways shall conform to the requirements of 29 CFR 1919.24**  **"Fixed Industrial Stairs".**  **Ladders 1. Portable ladders shall be capable of supporting at least f**  **our times the maximum intended load.**  **2. Portable metal or conductive ladders shall not be used near energi zed lines or equipment**  **except as may be necessary in specialized work such as high voltage substations where non**  **conductive ladders might present a greater hazard than conductive ladders. Conductive or**  **metal ladders shall be prominently marked a conductive and all nece ssary precautions shall**  **be taken when used in specialized work. 3. Ladder rungs, cleats and steps shall be parallel, level and unif**  **ormly spaced when the ladder is in position for use.**  **4. The minimum clear distance between side rails for all porta ble ladders shall be 11.5 inches.**  **5. The following requirements apply to the use of all ladders, including job-made la dders.**  **a. Ladders used for access to an upper landing surface, shall have s ide rails that extend**  **at least three feet above the landing surface. b. Ladders shall be maintained free of oil, grease and other slipping hazards.**  **c. Ladders shall be used only for the purpose for which they were designed. d. Non-self-supporting ladders shall be used at an angle such that t**  **he horizontal distance from the top support to the foot of the ladder is approxima**  **tely one-quarter of the working length of the ladder.**  **e. Non-self-supporting ladders shall be tied off or otherwise sec ured to prevent**  **accidental displacement. f. When ascending or descending a ladder, the user shall face the ladde**  **r and shall use at least one hand to grasp the ladder. The user shall not carry a**  **ny object or load that could cause him/her to lose balance and fall.**  **6. Ladders with structural defects, such as broken or missing rungs, shall be tagged DO NOT**  **USE, and shall be withdrawn from service. 7. Ladders will be inspected by a competent person and approved for**  **use before being put into service. Each user shall visually inspect ladder before using.**  **8. Ladders placed in any location where they can be displaced by w orkplace activities or traffic,**  **shall have warning signs posted. Extension Ladders**  **1. After the extension section has been raised to desired height, th e safety latches must be**  **engaged and the extension rope secured to a rung on the base section of the ladder before use.**  **2. Extension ladder sections are not to be used separately. Stepladders**  **1. Must be set level on all four feet, with spreaders locked on pla ce. Do not use as a straight**  **ladder. DEECO Health and Safety Plan Page 24 January 2010** 

**2. When used close to the edge of an elevated platform, roof or floor op ening, and when**  **location requirements so specify, they must be tied off, and employ ees using such a**  **stepladder shall wear fall-arresting equipment. 3. Employees using stepladders shall stand so that their waists**  **are below the top of the ladder. The President shall ensure that all employees are trained in the proper use**  **of ladders.** 2.22 Travel Safety **When driving any DEECO vehicle, or when driving your own personal vehicle when performing**  **DEECO related work, employees must:**

# **Obey all traffic rules and regulations.** # **Obey all traffic rules on a plant site.** # **Turn off vehicle and set brake when leaving vehicle.** # **Use horn at blind driveways or intersections with an obstructive view.** # **Have a valid North Carolina license to operate a DEECO vehicle and trailer.** # **Never pick up hitchhikers.** # **Perform a pre-trip check of vehicle(s) lights, horns, brakes, oil, etc.**

2.23 Thermal Stress **Thermal stress to the body can be caused when the body temperatur e is not in balance between body**  **heat production and heat loss to the surrounding environment. Heat stress is caused when the body**  **is unable to sufficiently cool the body, and cold stress is possibl e when the body is unable to**  **sufficiently heat the body.**

Heat Stress **Heat stress is a general term used to describe various degre es of heat illness. The temperature of the**  **body is a function of the amount of heat it produces and the amount of heat it can los e. When the**  **temperature of the environment approaches the body temperature, it becomes increasingly difficult**  **for the body to lose heat. Heat illness is possible when the body is not able to sufficiently cool itself.**  **The body can lose heat to the environment by three mechanisms. The m ost important is convection.**  **This is when the temperature of the skin is higher than that of the surrounding atmosphere.**  **Conduction is the transfer of heat from the body to a solid or liquid. An example would be the**  **immediate cooling of your face on a hot day by splashing cold wa ter on it. Both convection and**  **conduction can also be negative, meaning that if the atmosphere or ma terial in contact with the body**  **is warmer than the body itself, heat can be transferred to the body. The third, and comparably small, mechanism is respiration. This**  **is the warming and saturation of respired air while in the lungs.** 

Effects of Heat **The body possesses two physiological responses which enable it t o lose heat. The first is the dilation**  **(enlargement) of the blood vessels near the skin surface. This incr eases the flow of blood,**  **transferring heat to the skin. The skin temperature will increa se, and is cooled by either convection**  **on conduction. DEECO Health and Safety Plan Page 25 January 2010** 

**The second response is sweating. Sweating occurs when the increas e in blood flow to the skin does**  **not achieve the desired cooling effect. Heat is lost when sweat is evaporated from the body.** 

Heat Illness **Heat illness can be caused by either elevated body or skin temp eratures. Elevated body temperatures**  **can result in heat exhaustion, heat cramps, and heat stroke. Elevated skin temperatures can cause**  **skin-tissue damage.**

Heat Exhaustion **Heat exhaustion is caused by circulatory failure, where the amount of blood returned to the heart is**  **significantly reduced. Symptoms of heat exhaustion are fatigue, he adache, dizziness, loss of**  **appetite, nausea, abdominal pain, vomiting, shortness of breath, and puls e rates in excess of 150**  **beats per minute. Heat exhaustion can result in poor judgement, irri tability, and possibly fainting.**  **A person suffering from heat exhaustion can usually recover very quic kly if he/she is removed to a**  **cool place and allowed to lie down.** Heat Cramps **Heat cramps are muscle spasms which usually occur in the arm s, legs, back and abdomen. This is**  **due to excessive loss of salt from sweating. Heat cramps ca n be prevented by taking extra salt when**  **heavy work is carried out. It is recommended that employees do not take salt tablets, but rather**  **ensure that they eat at regular intervals during the course of the work, Extra salt can by added to the**  **body through eating.**

Heat Stroke **The most serious heat illness is heat stroke. When the body tem perature reaches a certain level,**  **sweating may stop. This will cause the body temperature to increase to critical levels. Such an**  **increase in body temperature can cause denaturization of proteins, enzyme degradation, changes in**  **the viscosity of cell protoplasm, and alterations in the physica l structure of the cell membranes.**  **Tissue damage and death are possible. Immediate medical attention is necessary for individuals sufferi**  **ng from heat stroke in order to avoid irreversible damage to the brain. The individual should be wrapped i**  **n cool, wet sheets. Immersion in a cold bath is not recommended, since a too rapid decrease in the**  **body temperature may result in tissue damage.** 

Precautions **1. Water intake must equal the amount of water lost due to sweat ing and excretion. In hot**  **environments, water intake must be forced since the body's normal thi rst mechanism is not**  **adequate to force the individual to drink. Continuous sweat rates of 1 to 2 liter s per hours**  **are not unusual. 2. Salt is lost during sweating. Additions of small amounts of salt to food may be nece**  **ssary. 3. Most importantly, frequent, short breaks during strenuous activities**  **allows the body to better adapt to the hot environment than infrequent long breaks. By taking shorte**  **r breaks, there is less cumulative fatigue and less demand on the heart and respiration.**  **4. It is possible for the body to acclimatize to hot environments. This may happen only if**  **successive days are spent in the hot environment (usually between 4 to 7). DEECO Health and Safety Plan Page 26 January 2010** 

Cold Stress **In cold environments, the body must increase its metabolic heat pro duction. In general, -30**  E **F is the lower limit for prolonged work. Unlike hot environments, individuals do**  **not acclimatize (physiologically adapt) to cold environments.**  **The wind-chill temperature, rather than the ambient temperature , best describe a cold environment.**  **Wind velocity adds to the rate of body cooling.**

Cold Illness Hypothermia **Hypothermia is a general cooling of the body temperature. Hypot hermia can occur in environments**  **above 32** E **F. Symptoms include excessive shivering, and numbness in extremiti es. The individual**  **should be moved to a warm environment. Alcohol should not be consumed, since t his will cause**  **the blood vessel to dilate, resulting in excessive body heat loss. Hot, non-alcoholic beverages should**  **be administered.**

Frost Bite **Frost bite can be either superficial or can penetrate be low the skin. Superficial frost bite can be**  **easily treated by warming the exposed skin with hands or other wa rmer part of the body (e.g. placing**  **hands under armpits). This will gradually warm the skin. Rapid w arming (exposure to fire, soaking**  **in cold water etc.) is not recommended since damage to the skin tis sue can occur. It is important to**  **note that pain will occur as the skin is thawed. When frost bite extends below the surface of the skin (from prolonged exposure**  **), it is essential to get immediate medical attention.** 

Precautions **1. Individuals should eat balanced meals and replace body liquids regula rly. Dehydration is as**  **prevalent in cold environments as it is in hot environments. Warm li quids are preferable**  **since they do not have to be warmed by the body after being consumed. 2. Proper protective clothing should be worn when exposed to cold environments.**  **3 Dexterity and judgement are both diminished in cold environments.** 2.24 Welding and Cutting **DEECO employees shall not perform any welding or cutting on a p roject site. The project**  **manager/field team leader shall ensure that the client contrac ts such work with qualified individuals.**  **DEECO employees shall leave the immediate area during any welding or cutting operations.**  2.26 Lockout/Tagout (LOTO) **Lockout/Tagout (LOTO) refers to specific practices and procedur es to safeguard employees from**  **the unexpected energization or startup of machinery and equipme nt, or the release of hazardous**  **energy during service or maintenance activities.** Under no circumstance should DEECO employee’s participate in LOTO **. Should any LOTO be necessary at a client’s facility, all LOTO**  **procedures are to be handled by the client or their representative. DEECO Health and Safety Plan Page 27 January 2010** 

2.27 Fall Protection 2.27.1 Determining When Fall Protection Must be Provided **DEECO shall determine if the walking/working surfaces on which it s employees are to work have**  **the strength and structural integrity to support employees safe ly. Employees shall be allowed to work**  **on those surfaces only when the surfaces have the requisite strength and structural int egrity.**  **Each employee on a walking/working surface (horizontal and vertical surface) with an unprotected**  **side or edge which is 6 feet (1.8 m) or more above a lower level shall be prot ected from falling by**  **the use of guardrail systems, safety net systems, or personal fall arres t systems.**  Hoist Areas **Each employee in a hoist area shall be protected from falling 6 feet (1.8 m) or more to lower levels**  **by guardrail systems or personal fall arrest systems. If guardrail systems, [or chain, gate, or guardrail]**  **or portions thereof, are removed to facilitate the hoisting ope ration (e.g., during landing of**  **materials), and an employee must lean through the access opening or out over the edge of the access**  **opening (to receive or guide equipment and materials, for example ), that employee shall be protected**  **from fall hazards by a personal fall arrest system.**

Holes **Each employee on walking/working surfaces shall be protecte d from falling through holes (including**  **skylights) more than 6 feet (1.8 m) above lower levels, by persona l fall arrest systems, covers, or**  **guardrail systems erected around such holes. Each employee on a walking/working surface shall be protected fr**  **om tripping in or stepping into or through holes (including skylights) by covers.**  **Each employee on a walking/working surface shall be protected fr om objects falling through holes**  **(including skylights) by covers.** Formwork and Reinforcing Steel **Each employee working on the face of formwork or reinforcing steel shall be protected from falling**  **6 feet (1.8 m) or more to lower levels by personal fall arrest systems, safety net systems, or**  **positioning device systems.** Ramps, Runways, and Other Walkways **Each employee on ramps, runways, and other walkways shall be protected from falling 6 feet (1.8**  **m) or more to lower levels by guardrail systems. DEECO Health and Safety Plan Page 28 January 2010** 

Excavations **Each employee at the edge of an excavation 6 feet (1.8 m) or more in depth shall be protected from**  **falling by guardrail systems, fences, or barricades when the e xcavations are not readily seen because**  **of plant growth or other visual barrier. Each employee at the edge of a well, pit, shaft, and similar e**  **xcavation 6 feet (1.8 m) or more in depth shall be protected from falling by guardrail systems, fences, barr**  **icades, or covers.** Dangerous Equipment **Each employee less than 6 feet (1.8 m) above dangerous equipment shal l be protected from falling**  **into or onto the dangerous equipment by guardrail systems or by equipment guards. Each employee 6 feet (1.8 m) or more above dangerous equipment shall**  **be protected from fall hazards by guardrail systems, personal fall arrest systems, or safe**  **ty net systems.** Overhand Bricklaying and Related Work **Currently, DEECO does not perform overhand bricklaying, so any fall p rotection programs related**  **to overhand brick are not applicable.** Working on Roofs **Each employee engaged in any activities on low-slope roofs (slo pe less than 4 in 12), with**  **unprotected sides and edges 6 feet (1.8 m) or more above lower level s shall be protected from falling**  **by guardrail systems, safety net systems, personal fall arres t systems, or a combination of warning**  **line system and guardrail system, warning line system and safe ty net system, or warning line system**  **and personal fall arrest system, or warning line system and safety monitori ng system.**  **Each employee on a steep roof (slope greater than 4 in 12) with unprotected sides and edges 6 feet**  **(1.8 m) or more above lower levels shall be protected from fa lling by guardrail systems with**  **toeboards, safety net systems, or personal fall arrest systems.**

Precast Concrete Erection **Currently, DEECO does not perform precast concrete erection, so a ny fall protection programs**  **related to precast concrete erection are not applicable.**

Residential Construction **Currently, DEECO does not perform residential construction, so any fa ll protection programs related**  **to residential construction are not applicable. DEECO Health and Safety Plan Page 29 January 2010** 

Wall Openings **Each employee working on, at, above, or near wall openings (including t hose with chutes attached)**  **where the outside bottom edge of the wall opening is 6 feet (1.8 m) or more above lower levels and**  **the inside bottom edge of the wall opening is less than 39 inches ( 1.0 m) above the walking/working**  **surface, shall be protected from falling by the use of a guar drail system, a safety net system, or a**  **personal fall arrest system.** Walking/Working Surfaces Not Otherwise Addressed (e.g Man Lifts) **When operating or working on any man lifts that fall under the ANS I standard definition that**  **includes certain vehicle-mounted elevating and rotating work platforms , namely "extensible boom**  **platforms," "aerial ladders," "articulating boom platforms," " vertical towers," and "a combination**  **of any of the above.", DEECO employees shall be protected from f alling by a personal fall arrest**  **system. For all other walking/working surfaces not otherwise addressed, each**  **employee on a walking/working surface 6 feet (1.8 m) or more above lower levels shall be**  **protected from falling by a guardrail system, safety net system, or personal fall arrest sys**  **tem.** Protection from Falling Objects **When an employee is exposed to falling objects, the employer sha ll have each employee wear a hard**  **hat and shall erect toeboards, screens, or guardrail systems to p revent objects from falling from**  **higher levels, erect a canopy structure and keep potential fall objects far enough from the edge of the**  **higher level so that those objects would not go over the edge if they were accidentally displaced; or,**  **barricade the area to which objects could fall, prohibit employe es from entering the barricaded area,**  **and keep objects that may fall far enough away from the edge of a higher level so that those objects**  **would not go over the edge if they were accidentally displaced. The project manager/field team leader must check with clien**  **t's representative to see if additional barricade procedures specific to their facility are required.**  2.27.2 Guidelines for Fall Protection **The DEECO project manager/field team in conjunction with the client's representative shall**  **determine when additional fall protection is required. The client shall provide and install all Guard Rail Systems, Sa**  **fety Net Systems, Positioning Device Systems and Warning Line Systems required for DEECO an employ**  **ee, and shall comply with all other pertinent requirements of described below before that empl**  **oyee begins the work that necessitates the fall protection.**  Guardrail Systems **Top edge height of top rails, or equivalent guardrail system me mbers, shall be 42 inches (1.1 m) plus**  **or minus 3 inches (8 cm) above the walking/working level. When conditions w arrant, the height of** **DEECO Health and Safety Plan Page 30 January 2010**

**the top edge may exceed the 45-inch height, provided the guardrail system meets all other criteria**  **of this paragraph. Note: When employees are using stilts, the top edge height of t**  **he top rail, or equivalent member, shall be increased an amount equal to the height of the stilts.**  **Midrails, screens, mesh, intermediate vertical members, or equiva lent intermediate structural**  **members shall be installed between the top edge of the guardrail s ystem and the walking/working**  **surface when there is no wall or parapet wall at least 21 inches (53 cm) high. Midrails, when used, shall be installed at a height midway be**  **tween the top edge of the guardrail system and the walking/working level.**  **Screens and mesh, when used, shall extend from the top rail to the w alking/working level and along**  **the entire opening between top rail supports. Intermediate members (such as balusters), when used between p**  **osts, shall be not more than 19 inches (48 cm) apart.**  **Other structural members (such as additional midrails and archit ectural panels) shall be installed**  **such that there are no openings in the guardrail system that are more than 19 inches (.5 m ) wide.**  **Guardrail systems shall be capable of withstanding, without failure, a f orce of at least 200 pounds**  **(890 N) applied within 2 inches (5.1 cm) of the top edge, in any outward or downward direction, at**  **any point along the top edge. When the 200 pound (890 N) test load specified above is applied in a downwa**  **rd direction, the top edge of the guardrail shall not deflect to a height less than 39 inc**  **hes (1.0 m) above the walking/working level.**  **Midrails, screens, mesh, intermediate vertical members, solid p anels, and equivalent structural**  **members shall be capable of withstanding, without failure, a f orce of at least 150 pounds (666 N)**  **applied in any downward or outward direction at any point along the midrail or other membe r.**  **Guardrail systems shall be so surfaced as to prevent injury to an employee from punctures or**  **lacerations, and to prevent snagging of clothing. The ends of all top rails and midrails shall not overhang the term**  **inal posts, except where such overhang does not constitute a projection hazard.**  **Steel banding and plastic banding shall not be used as top rails or midrail s.**  **Top rails and midrails shall be at least one-quarter inch (0.6 cm) nominal diam eter or thickness to**  **prevent cuts and lacerations. If wire rope is used for top rai ls, it shall be flagged at not more than 6-**  **foot intervals with high-visibility material. When guardrail systems are used at hoisting areas, a chain, gate**  **or removable guardrail section shall be placed across the access opening between guardrail sect**  **ions when hoisting operations are not taking place.** **DEECO Health and Safety Plan Page 31 January 2010**

**When guardrail systems are used at holes, they shall be erecte d on all unprotected sides or edges of**  **the hole. When guardrail systems are used around holes used for the passage of**  **materials, the hole shall have not more than two sides provided with removable guardrail sections to**  **allow the passage of materials. When the hole is not in use, it shall be closed over wit**  **h a cover, or a guardrail system shall be provided along all unprotected sides or edges.**  **When guardrail systems are used around holes which are used as poi nts of access (such as**  **ladderways), they shall be provided with a gate, or be so offset that a person cannot walk directly into**  **the hole. Guardrail systems used on ramps and runways shall be erected al**  **ong each unprotected side or edge. Manila, plastic or synthetic rope being used for top rails or**  **midrails shall be inspected as frequently as necessary to ensure that it continues to meet the strength re**  **quirements of paragraph (b)(3) of this section.**  Safety Net Systems **Safety nets shall be installed as close as practicable unde r the walking/working surface on which**  **employees are working, but in no case more than 30 feet (9.1 m) below such le vel. When nets are**  **used on bridges, the potential fall area from the walking/wor king surface to the net shall be**  **unobstructed. Safety nets shall extend outward from the outermost projection of the work surfac**  **e as follows: Vertical distance from working level to**  **horizontal plane of net Minimum required horizontal distance of**  **outer edge of net from the edge of the**

**working surface Up to 5 feet 8 feet**  **More than 5 feet up to 10 feet 10 feet More than 10 feet 13 feet**  **Safety nets shall be installed with sufficient clearance under them to prevent contact with the surface**  **or structures below when subjected to an impact force equal to the drop test described below. Safety**  **nets and their installations shall be capable of absorbing an i mpact force equal to that produced by**  **the drop test described below. Except as described below, safety nets and safety net instal**  **lations shall be drop-tested at the jobsite after initial installation and before being used as a fall pr**  **otection system, whenever relocated, after major repair, and at 6-month intervals if left in one place. The dr**  **op-test shall consist of a 400 pound (180 kg) bag of sand 30 + or - 2 inches (76 + or - 5 cm) in diameter dropped i**  **nto the net from the highest walking/working surface at which employees are exposed t**  **o fall hazards, but not from less than 42 inches (1.1 m) above that level.** **DEECO Health and Safety Plan Page 32 January 2010**

**When the employer can demonstrate that it is unreasonable to perform the drop-test, the employer**  **(or a designated competent person) shall certify that the net a nd net installation is in compliance with**  **the provisions of paragraphs (c)(3) and (c)(4)(i) of this secti on by preparing a certification record**  **prior to the net being used as a fall protection system. The c ertification record must include an**  **identification of the net and net installation for which the certifi cation record is being prepared; the**  **date that it was determined that the identified net and net instal lation were in compliance with**  **paragraph (c)(3) of this section and the signature of the person m aking the determination and**  **certification. The most recent certification record for each net and net installation shall be available**  **at the jobsite for inspection. Defective nets shall not be used. Safety nets shall be inspect**  **ed at least once a week for wear, damage, and other deterioration. Defective components shall be removed**  **from service. Safety nets shall also be inspected after any occurrence which could affect**  **the integrity of the safety net system. Materials, scrap pieces, equipment, and tools which have fallen int**  **o the safety net shall be removed as soon as possible from the net and at least before the next work shift.**  **The maximum size of each safety net mesh opening shall not exc eed 36 square inches (230 cm) nor**  **be longer than 6 inches (15 cm) on any side, and the opening, measur ed center-to-center of mesh**  **ropes or webbing, shall not be longer than 6 inches (15 cm). All mes h crossings shall be secured to**  **prevent enlargement of the mesh opening. Each safety net (or section of it) shall have a border rope f**  **or webbing with a minimum breaking strength of 5,000 pounds (22.2 kN).**  **Connections between safety net panels shall be as strong as int egral net components and shall be**  **spaced not more than 6 inches (15 cm) apart.** Personal Fall Arrest Systems **Personal fall arrest systems shall consist of a full body har ness. Body belts are not acceptable as part**  **of a personal fall arrest system except in a positioning device system as described below.**  **Connectors shall be drop forged, pressed or formed steel, or made of equivalent materials and shall**  **have a corrosion-resistant finish. All surfaces and edges sha ll be smooth to prevent damage to**  **interfacing parts of the system. Dee-rings and snaphooks shall have a minimum tensile strength of 5,000 pounds**  **(22.2 kN) and shall be proof-tested to a minimum tensile load of 3,600 pounds (16 kN) without cra**  **cking, breaking, or taking permanent deformation.**  **Snaphooks shall be sized to be compatible with the member to whi ch they are connected to prevent**  **unintentional disengagement of the snaphook by depression of the snaphoo k keeper by the connected**  **member, or shall be a locking type snaphook designed and used to prev ent disengagement of the**  **snaphook by the contact of the snaphook keeper by the connected mem ber. Only locking type**  **snaphooks shall be used. DEECO Health and Safety Plan Page 33 January 2010** 

**Unless the snaphook is a locking type and designed for the following conne ctions, snaphooks shall**  **not be engaged directly to webbing, rope or wire rope, to each ot her, to a dee-ring to which another**  **snaphook or other connector is attached, to a horizontal lifeline; or to a ny object which is**  **incompatibly shaped or dimensioned in relation to the snaphook such that unintentional**  **disengagement could occur by the connected object being able to depr ess the snaphook keeper and**  **release itself. On suspended scaffolds or similar work platforms with horizontal l**  **ifelines which may become vertical lifelines, the devices used to connect to a horizontal lifeline shal**  **l be capable of locking in both directions on the lifeline. Horizontal lifelines shall be des**  **igned, installed, and used, under the supervision of a qualified person, as part of a complete personal**  **fall arrest system, which maintains a safety factor of at least two.**  **Lanyards and vertical lifelines shall have a minimum breaking st rength of 5,000 pounds (22.2 kN).**  **Lifelines shall be protected against being cut or abraded. Se lf-retracting lifelines and lanyards which**  **automatically limit free fall distance to 2 feet (0.61 m) or less shall be capable of sustaining a**  **minimum tensile load of 3,000 pounds (13.3 kN) applied to the device with the lifeline or lanya rd**  **in the fully extended position. Self-retracting lifelines and lanyards which do not limit free**  **fall distance to 2 feet (0.61 m) or less, ripstitch lanyards, and tearing and deforming lanyards shall be ca**  **pable of sustaining a minimum tensile load of 5,000 pounds (22.2 kN) applied to the device with the lifeli**  **ne or lanyard in the fully extended position.**  **Ropes and straps (webbing) used in lanyards, lifelines, and streng th components of body belts and**  **body harnesses shall be made from synthetic fibers. Anchorages used for attachment of personal fall arrest equipment**  **shall be independent of any anchorage being used to support or suspend platforms and capable of**  **supporting at least 5,000 pounds (22.2 kN) per employee attached, or shall be designed, install**  **ed, and used as part of a complete personal fall arrest system which maintains a saf**  **ety factor of at least two and under the supervision of a qualified person.**  **Personal fall arrest systems, when stopping a fall, shall limit maximum arresting force on an**  **employee to 900 pounds (4 kN) when used with a body belt, limit maximum arresting force on an**  **employee to 1,800 pounds (8 kN) when used with a body harness, be rigged s uch that an employee**  **can neither free fall more than 6 feet (1.8 m), nor contact any lower level, bring an employee to a**  **complete stop and limit maximum deceleration distance an emp loyee travels to 3.5 feet (1.07 m)**  **and, have sufficient strength to withstand twice the potential impa ct energy of an employee free**  **falling a distance of 6 feet (1.8 m), or the free fall distance permitted by the system, whichever is**  **less. The attachment point of the body belt shall be located in the cen**  **ter of the wearer's back. The attachment point of the body harness shall be located in the center**  **of the wearer's back near shoulder level, or above the wearer's head.**  **Body belts, harnesses, and components shall be used only for employee protection (as part of a**  **personal fall arrest system or positioning device system) and not to hoist mat erials.** **DEECO Health and Safety Plan Page 34 January 2010**

**Personal fall arrest systems and components subjected to imp act loading shall be immediately**  **removed from service and shall not be used again for employee prot ection until inspected and**  **determined by a competent person to be undamaged and suitable for reuse. The employer shall provide for prompt rescue of employees in the**  **event of a fall or shall assure that employees are able to rescue themselves.**  **Personal fall arrest systems shall be inspected prior to e ach use for wear, damage and other**  **deterioration, and defective components shall be removed from service. Body belts shall be at least one and five-eighths (1 5/8) inches (4.1 cm) wide.**  **Personal fall arrest systems shall not be attached to guardra il systems, nor shall they be attached to**  **hoists. When a personal fall arrest system is used at hoist a reas, it shall be rigged to allow the**  **movement of the employee only as far as the edge of the walking/working surface.** Positioning Device Systems **Positioning device systems shall be rigged such that an employee cannot free fall more than 2 feet**  **(.9 m). Positioning devices shall be secured to an anchorage capabl e of supporting at least twice the**  **potential impact load of an employee's fall or 3,000 pounds (13.3 kN), whichever is great er.**  **Connectors shall be drop forged, pressed or formed steel, or made of equivalent materials and shall**  **have a corrosion-resistant finish. All surfaces and edges shall be smooth to prevent damage to**  **interfacing parts of this system. Connecting assemblies shall have a minimum tensile strength of**  **5,000 pounds (22.2 kN). Dee-rings and snaphooks shall be proof-tested to a minimum tensile**  **load of 3,600 pounds (16 kN) without cracking, breaking, or taking permanent deformation.**  **Snaphooks shall be sized to be compatible with the member to whi ch they are connected to prevent**  **unintentional disengagement of the snaphook by depression of the snaphook keeper by the connected**  **member, or shall be a locking type snaphook designed and used to preven t disengagement of the**  **snaphook by the contact of the snaphook keeper by the connected member. A s of January 1, 1998,**  **only locking type snaphooks shall be used. Unless the snaphook is a locking type and designed for the following conne**  **ctions, snaphooks shall not be engaged directly to webbing, rope or wire rope, to each ot**  **her, to a dee-ring to which another snaphook or other connector is attached, to a horizontal lifeline;**  **or to any object which is incompatibly shaped or dimensioned in relation to the snaphook such t**  **hat unintentional disengagement could occur by the connected object being able to depr**  **ess the snaphook keeper and release itself.**  **Positioning device systems shall be inspected prior to each use for wear, damage, and other**  **deterioration, and defective components shall be removed from service. Body belts, harnesses, and components shall be used only for employee**  **protection (as part of a personal fall arrest system or positioning device system) and not to hoist mat**  **erials. DEECO Health and Safety Plan Page 35 January 2010** 

Warning Line Systems **Warning line systems shall be erected around all sides of the r oof work area. When mechanical**  **equipment is not being used, the warning line shall be erected not l ess than 6 feet (1.8 m) from the**  **roof edge. When mechanical equipment is being used, the warning line shall be erected not less than**  **6 feet (1.8 m) from the roof edge which is parallel to the direct ion of mechanical equipment**  **operation, and not less than 10 feet (3.1 m) from the roof edge which is perpendicular to the direction**  **of mechanical equipment operation. Points of access, materials handling areas, storage areas, and hoi**  **sting areas shall be connected to the work area by an access path formed by two warning lines. When t**  **he path to a point of access is not in use, a rope, wire, chain, or other barricade, equivalent in strengt**  **h and height to the warning line, shall be placed across the path at the point where the path int**  **ersects the warning line erected around the work area, or the path shall be offset such that a person cannot**  **walk directly into the work area. Warning lines shall consist of ropes, wires, or chains, and supporti**  **ng stanchions erected as follows: 1. The rope, wire, or chain shall be flagged at not more than 6-foot**  **(1.8 m) intervals with high visibility material;**  **2. The rope, wire, or chain shall be rigged and supported in such a w ay that its lowest point**  **(including sag) is no less than 34 inches (.9 m) from the walking/worki ng surface and its**  **highest point is no more than 39 inches (1.0 m) from the walking/working surface; 3. After being erected, with the rope, wire, or chain attached**  **, stanchions shall be capable of resisting, without tipping over, a force of at least 16 pounds (71**  **N) applied horizontally against the stanchion, 30 inches (.8 m) above the walking/working surface**  **, perpendicular to the warning line, and in the direction of the floor, roof, or platform edge;**  **4. The rope, wire, or chain shall have a minimum tensile strength of 500 pounds (2.22 kN), and**  **after being attached to the stanchions, shall be capable of sup porting, without breaking, the**  **loads applied to the stanchions as described above; and 5. The line shall be attached at each stanchion in such a way that**  **pulling on one section of the line between stanchions will not result in slack being taken up i**  **n adjacent sections before the stanchion tips over.**  **No employee shall be allowed in the area between a roof edge a nd a warning line unless the**  **employee is performing roofing work in that area. Mechanical equipment on roofs shall be used or stored only in areas w**  **here employees are protected by a warning line system, guardrail system, or personal fall arrest sys**  **tem.** Controlled Access Zone **When used to control access to areas where leading edge and other opera tions are taking place the**  **controlled access zone shall be defined by a control line or by any other means that restricts access.** **DEECO Health and Safety Plan Page 36 January 2010**

**When control lines are used, they shall be erected not less than 6 f eet (1.8 m) nor more than 25 feet**  **(7.7 m) from the unprotected or leading edge, except when erecting precast concrete members.**  **DEECO does not erecting precast concrete members. The control line shall extend along the entire**  **length of the unprotected or leading edge and shall be approximatel y parallel to the unprotected or**  **leading edge. The control line shall be connected on each side to a guardrail system or wall.**  **Additional control lines shall be erected at each end to enclose the controlled acce ss zone.**  **Control lines shall consist of ropes, wires, tapes, or equivalent m aterials, and supporting stanchions.**  **Each line shall be flagged or otherwise clearly marked at not more than 6-foot (1.8 m) intervals with**  **high-visibility material. Each line shall be rigged and suppor ted in such a way that its lowest point**  **(including sag) is not less than 39 inches (1 m) from the walking/wor king surface and its highest**  **point is not more than 45 inches (1.3 m) from the walking/working surface . Each line shall have a**  **minimum breaking strength of 200 pounds (.88 kN).** Safety Monitoring Systems **DEECO shall designate a competent person as the safety monitor . The safety monitor will monitor**  **the safety of other employees. The safety monitor shall be com petent to recognize fall hazards. The**  **safety monitor shall warn the employee when it appears that the employee is unaware of a fall hazard**  **or is acting in an unsafe manner. The safety monitor shall be on t he same walking/working surface**  **and within visual sighting distance of the employee being monitored. The safety moni tor shall be**  **close enough to communicate orally with the employee. The safety monitor shall not have other**  **responsibilities which could take the monitor's attention from the monitoring functi on.**  **Mechanical equipment shall not be used or stored in areas where sa fety monitoring systems are being**  **used to monitor employees engaged in roofing operations on low-slope roofs. No employee, other**  **than an employee engaged in roofing work [on low-sloped roofs] or an em ployee covered by a fall**  **protection plan, shall be allowed in an area where an employee i s being protected by a safety**  **monitoring system. Each employee working in a controlled access zone shall be direct**  **ed to comply promptly with fall hazard warnings from safety monitors.** 

Covers **Covers located in roadways and vehicular aisles shall be capable of supporting , without failure, at**  **least twice the maximum axle load of the largest vehicle ex pected to cross over the cover. All other**  **covers shall be capable of supporting, without failure, at leas t twice the weight of employees,**  **equipment, and materials that may be imposed on the cover at any one time. All covers shall be**  **secured when installed so as to prevent accidental displacement b y the wind, equipment, or**  **employees. All covers shall be color coded or they shall be ma rked with the word "HOLE" or**  **"COVER" to provide warning of the hazard.** Protection from Falling Objects **Toeboards, when used as falling object protection, shall be erected al ong the edge of the overhead**  **walking/working surface for a distance sufficient to protect employee s below. Toeboards shall be** **DEECO Health and Safety Plan Page 37 January 2010**

**capable of withstanding, without failure, a force of at least 50 pounds (222 N) applied in any**  **downward or outward direction at any point along the toeboard. Toeboards s hall be a minimum of**  **3 1/2 inches (9 cm) in vertical height from their top edge to the level of the walking/working surface.**  **They shall have not more than 1/4 inch (0.6 cm) clearance above the wal king/working surface. They**  **shall be solid or have openings not over 1 inch (2.5 cm) in greatest dimension. Where tools,**  **equipment, or materials are piled higher than the top edge of a toeboard, paneling or screening shall**  **be erected from the walking/working surface or toeboard to the top of a guardra il system's top rail**  **or midrail, for a distance sufficient to protect employees below. Guardrail systems, when used as**  **falling object protection, shall have all openings small enough to prevent passage of potential falling**  **objects. Canopies, when used as falling object protection, shall be strong**  **enough to prevent collapse and to prevent penetration by any objects which may fall onto the canopy.** 

Fall Protection Plan **This option is available only to employees engaged in leading edge work that it is infeasible or it**  **creates a greater hazard to use conventional fall protection equipment. The fall protection plan shall be prepared by a qualified per**  **son and developed specifically for the site where the leading edge work, precast concrete work, or residential constr**  **uction work is being performed and the plan must be maintained up to date. Any changes t**  **o the fall protection plan shall be approved by a qualified person. A copy of the fall protection**  **plan with all approved changes shall be maintained at the job site. The implementation of the fal**  **l protection plan shall be under the supervision of a competent person. The fall protection plan shall**  **document the reasons why the use of conventional fall protection systems (guardrail systems, pers**  **onal fall arrest systems, or safety nets systems) are infeasible or why their use would create a greater hazard.**  **The fall protection plan shall include a written discussion of ot her measures that will be taken to**  **reduce or eliminate the fall hazard for workers who cannot be provide d with protection from the**  **conventional fall protection systems. For example, the employer s hall discuss the extent to which**  **scaffolds, ladders, or vehicle mounted work platforms can be used to pr ovide a safer working surface**  **and thereby reduce the hazard of falling. The fall protection plan shall identify each location where convent**  **ional fall protection methods cannot be used. These locations shall then be classified as controll**  **ed access zones. Where no other alternative measure has been implemented, the employer shall**  **implement a safety monitoring system.**  **The fall protection plan must include a statement which provides the name or other method of**  **identification for each employee who is designated to work in cont rolled access zones. No other**  **employees may enter controlled access zones. In the event an employee falls, or some other related, serious inci**  **dent occurs, (e.g., a near miss) the employer shall investigate the circumstances of the fall or ot**  **her incident to determine if the fall protection plan needs to be changed (e.g. new practices, procedures,**  **or training) and shall implement those changes to prevent similar types of falls or incidents.** **DEECO Health and Safety Plan Page 38 January 2010**

2.27.3 Fall Protection Training Program **DEECO shall provide a training program for each employee who mi ght be exposed to fall hazards.**  **The program shall enable each employee to recognize the haza rds of falling and shall train each**  **employee in the procedures to be followed in order to minimize these hazards. DEECO shall assure that each employee has been trained, as**  **necessary, by a competent person qualified in the nature of fall hazards in the work area, the correc**  **t procedures for erecting, maintaining, disassembling, and inspecting the fall protection sy**  **stems to be used, the use and operation of guardrail systems, personal fall arrest system**  **s, safety net systems, warning line systems, safety monitoring systems, controlled access zones, and other protec**  **tion to be used, the role of each employee in the safety monitoring system when this system**  **is used, the limitations on the use of mechanical equipment during the performance of roofing work on low-slo**  **ped roofs, the correct procedures for the handling and storage of equipment and materials and**  **the erection of overhead protection; and the role of employees in fall protection plans.**  Certification of Training **DEECO shall verify compliance with the Fall Protection Training Program by preparing a written**  **certification record. The written certification record shall contain the na me or other identity of the**  **employee trained, the date(s) of the training, and the signature of the person who conducted the**  **training or the signature of the employer. If training is conducted b y another employer, the**  **certification record shall indicate the date the employer deter mined the prior training was adequate**  **rather than the date of actual training. The latest training certification shall be maintained.**  Retraining **When DEECO has reason to believe that any affected employee who has already been trained does**  **not have the understanding and skill required by the Fall Protection Tra ining Program, DEECO shall**  **retrain each such employee. Circumstances where retraining is required include, but are not limited**  **to, situations where changes in the workplace render previous traini ng obsolete, changes in the types**  **of fall protection systems or equipment to be used render previous training obsolete, or inadequacies**  **in an affected employee's knowledge or use of fall protection sys tems or equipment indicate that the**  **employee has not retained the requisite understanding or skill.** 2.28 Combustible Gas (LEL), Carbon Monoxide, Hydrogen Sulfide, and/or Oxygen Monitors **For safe operation around processes involving combustible material s, a hot work permit may be**  **required. Hot work permits (HWPs) are required for any process where testing activities may**  **produce an ignition source in a work area in which flammable vapors or gases may be present. To**  **issue an HWP, a hazard assessment must be performed. To do so, combus tible gas and vapor**  **concentrations must be determined for the work area and job classi fication in question, then**  **compared to acceptable standards. These surveys typically invol ve the use of combustible gas**  **meters-also called lower explosive limit (LEL) meters. The se surveys are conducted by the client**  **personnel issuing the hot work permits . DEECO Health and Safety Plan Page 39 January 2010** 

**To perform the surveys properly, the facility will have work i nstructions and standard operating**  **procedures (SOPs) developed, implemented and documented. Training in LEL instrument use,**  **instrument calibration, sampling strategy, continuous or follow-up monitor ing, tracking of denied**  **permits, communication between departments related to the content of processes, documentation of**  **results, auditing of hot work permit procedures and results, and the cont inuous improvement of those**  **SOPs will be addressed. In some cases DEECO will be required to provide additional monitori**  **ng for LEL, carbon monoxide, hydrogen sulfide, and/or oxygen. For these situations, DEECO personnel will be t**  **rained in LEL, carbon monoxide, hydrogen sulfide, and/or oxygen instrument use and instrument calibration.**  Training in Instrument Use **Thorough, documented training will be performed for the use of LEL, ca rbon monoxide, hydrogen**  **sulfide, and/or oxygen meters. Thus, training programs for operat ors of LEL, carbon monoxide,**  **hydrogen sulfide, and/or oxygen meters will include: 1. Work instructions for basic instrument use;**  **2. Theory of instrument operation; 3 Instrument maintenance and calibration; and**  **4. Recordkeeping for calibration and maintenance.**

Instrument Calibration **The instrument manufacturers detail procedures for calibrating LEL, c arbon monoxide, hydrogen**  **sulfide, and/or oxygen meters will be followed. Calibration includes; 1. Clean air-zero point calibration;**  **2. Calibration of response with the appropriate span gas; 3. Checking and calibration, for actively pumped meters, of the air flow rate in t**  **he system; 4. Fault detection and subsequent maintenance; and**  **5. Record keeping. Any decisions made to extend the period between calibrations or to**  **lessen the rigor of calibrations must first be formally evaluated by qualified persons against**  **the manufacturer's recommendations, industry best practices and governmental regulations. Requirements**  **for specified, periodic calibration of zero, span and flow are mandates, not recommendations. T**  **his applies for all systems, but is especially critical for systems used in environments w**  **here air contaminants that may degrade the meter's sensing element may be present.** **DEECO Health and Safety Plan Page 40 January 2010**

**For gases and vapors other than those for which a device was calibr ated, the manufacturer's**  **instructions and correction curves should be consult. Variations in re sponse that may result in**  **incorrect readings from such interferences as: 1. Oxygen concentration;**  **2. Gas pressure; 3. Sensor poisons (i.e., silicon, silicates and organic lead, acid g**  **ases) and sensor depressants (i.e., chlorinated hydrocarbons, acid gases); and**  **4. The fact that no reading will occur, or is even possible, for t he detection of combustible**  **airborne mists or dusts, such as lubricating oils, coal dust or grain dust. The portion of the calibration that deals with instrument airflow**  **rate must include the blocked flow alarm must being tested before and after each use. While this**  **is a requirement for all such systems, it is especially critical for instruments used in dusty environments.**  Sampling Strategy **Measurement of values for each atmospheric parameter should be m ade for at least the minimum**  **response time of the instrument. When monitoring operations involving a descent into atmospheres**  **that may be stratified, the atmospheric envelope should be tested a dista nce of approximately four**  **feet in the direction of travel and to each side. If a sampli ng probe is used, the rate of progress**  **should be slowed to accommodate the sampling speed and detector response . Any reading greater than zero should be followed by an assessment to:**  **1. Determine the source of the flammable vapors; 2. Eliminate the source, if possible; and**  **3. Ensure control of the source so that concentrations will not exceed ( at most) 10% of the LEL**  **at any location where it is possible that an ignition source may be present**

**.** Continuous or Follow-Up Monitoring **Continuous or follow-up monitoring may be required under conditions where the process, sequence**  **of work instructions or ambient conditions might reasonably be expec ted to change in a manner that**  **might increase the concentration of flammable gas or vapor. If conditions change during the course**  **of the permit period in a way that presents or could present ad ditional hazards, then work will be**  **terminated until the area or conditions are made safe and permit conditions are re -evaluated.**  **Processes that may affect the composition, concentration, flow ra te or volume, pressure and/or**  **temperature of flammable liquids, vapors or gases; 1. Processes adjacent to the process at which hot work is being performed;** **DEECO Health and Safety Plan Page 41 January 2010**

**2. Ambient conditions such as temperature, wind direction and wind speed; and 3. Other factors, such as the presence of uncontrolled vehicular traff**  **ic and/or ignition sources.** Documentation of Results (Record Keeping) **Each monitor obtained by DEECO will be assign a unique equipme nt identification (control) number**  **and complete records, including periodic performance, calibration and maintenance checks will be**  **maintained.** 2.29 Emergency Response/Evacuation Program **While at a client’s facility, follow their Emergency Respons e/Evacuation Program. The project**  **manager/field team leader will ensure that the employees a re aware of the facilities’ Emergency**  **Response/Evacuation Program. Their plan should address the following; 1. Procedures for reporting a fire or other emergency;**  **2. Procedures for emergency evacuation, including type of evacuation and e xit route**  **assignments; 3. Procedures to account for all employees after evacuation (head count);**  **4. Procedures to be followed by employees performing rescue or medical duti es; and**  **5. The name or job title of every employee who may be contacted by employees who need more**  **information about the plan or an explanation of their duties under the plan. Otherwise, when working at DEECO’s office, the following Emerge**  **ncy Response/Evacuation procedures should be followed;**  **1. Report a fires or other emergencies by dialing 911. Administer first aid and/or CPR if you**  **trained. Do not attempt to fight any fires unless you have been tr ained in the use of fire**  **extinguishers; 2. Should an evacuation be necessary follow the escape route assignme**  **nts. Exit diagrams are place throughout the office to identify the escape routes to be foll**  **owed by employees from each specific facility location. Assist in the evacuation of any visitors and cont**  **ractors; 3. Account for employees after the evacuation to ensure that everyone**  **got out. Designated employees will sweep areas, checking offices and rest rooms, b**  **efore being the last to leave a workplace or conducting a roll call in the assembly area; and**  **4. Account for any visitors and contractors using the Visitors and Contractors Sign In Log**

**. DEECO Health and Safety Plan Page 42 January 2010** 

2.30 Compressed Air Systems **DEECO employees are not allowed to operate pneumatic powe r tools or use the compressed air**  **systems, air hoses, or air lines associated with pneumatic power tools.**

2.31 Concrete Construction **DEECO employees are not allowed perform any concrete work, as described in OS HA 1926.700-**  **706.**

2.32 Powder-Actuated Tools **DEECO employees are not allowed to use powder-actuated tools, as described in OSHA 1926.302**  **(e). DEECO Health and Safety Plan Page 43 January 2010** 



### 3.0 Chemical Safety Guidelines **The procedures and guidelines detailed in the following sections are to be used by DEECO Field**  **personnel while performing work on either DEECO or client premis es. If the client has additional**  **safety procedures, Field personnel are to follow the procedures whi ch are more stringent. In all**  **cases, all OSHA and/or EPA requirements shall be met. Field personnel are to refer to the Material Safety Data S**  **heet and chemical labels for specific procedures and handling requirements. Copies of MSDSs for each chem**  **ical used, as well as for each chemical Field personnel may be exposed to while on a client's site, must b**  **e made available. The client is responsible for ensuring that MSDSs for chemicals us**  **ed on the work site are available for review. All Field personnel should refer to these MSDSs and be**  **familiar with the properties and handling requirements of all chemicals that may be used or encountered.**  **The required level of personal protective equipment for specific chemical hazards discussed in the**  **following sections depends on the situations at the work site. Decis ions on the appropriate**  **equipment to be worn should be made by the project manager or coordinator. The following information is DEECO's Chemical Hygiene Plan. Its intent**  **is to protect laboratory employees from health hazards associated with the use of hazardous**  **chemicals in our laboratory and to assure that our laboratory employees are not exposed to substances in exc**  **ess of the permissible exposure limits as defined by OSHA in 29 CFR 1910 subpart Z.**  **The plan is available to all employees fro review and a copy will be located in the Health and Safety**  **files. The plan will be reviewed annually by the Health and Sa fety Officer and/or the directors of**  **DEECO. The following sections of this document and throughout the manual are sta**  **ndard operating procedures for which each DEECO employee has received adequate tr**  **aining and direction. If questions exist for the following information, it may be found throughout**  **this manual or in our memo file. It is the responsibility of each employee to be**  **aware of DEECO's standard operating procedures for the following:**  **Accidents, spills, avoidance of routine exposure, choice of chemicals , eating-drinking-smoking,**  **equipment and glassware, horseplay, mouth suction, personal apparel, house keeping, personal**  **protection, planning, unattended operations, use of the hood, waste disposal a nd storage, working**  **alone, corrosives, fires, explosions, low temperature, pressurized and vacuum operations,**  **compressed gasses, chemical storage. The following operations shall be performed in the LABORATORY FUME HOO**  **D: - Use of solvents unless in outdoor work areas**  **- Use of open flames or burning devices - Use of any organic or inorganic chemical or compound that is unstable**  **These include preparation of standards, transfer of solvents, disposal or consolidat ion of waste** **DEECO Health and Safety Plan Page 44 January 2010**

**Respirators shall be used in accordance with DEECO's respira tory protection policy and with the**  **OSHA respirator standard 29 CFR 1910.134. This policy and associated docum entation is filed in**  **the office of the Health and Safety Officer and/or safety files. Appropriate protective apparel compatible with the required de**  **gree of protection for substances handled shall be used. The Health and Safety Officer is availab**  **le to advise employees on glove, gown, eye protection, barrier creams, etc, use. Permeability**  **Charts are available in any safety catalog such as Lab Safety Supply, or SAFECO. Use of tradenames or r**  **eferences does not indicate a recommendation or approval of listed products or Companies.**  **All eyewash stations are clearly marked and identified by the use of green placards and red arrows**  **leading to the eyewash areas. Employees who need to use the eyewashes are ins tructed as to their**  **use and must irrigate for a minimum of 15 minutes and seek medical assistance immediately.**  **Eyewashes will be inspected by the safety officer every month. Employees have been issued a memorandum as to the procedures to foll**  **ow for fires and explosions. Exit routes are marked in each employee area.**  **Fume hoods will be inspected every six months by the Health and Sa fety Officer. Adequacy of face**  **velocity will be determined by the use of a propeller anemome ter and must reach a minimum of 200**  **fpm. An employee may request a hood inspection at any time should t hey suspect a problem with**  **the hood or ventilation system. No employee will work with any hazardous chemicals unless they have**  **been instructed by their project manager or health and safety officer. These chemic**  **als include; carcinogens, explosives, neurotoxins, reproductive damaging chemicals, or acutely hazardous chemicals.**  **DEECO shall provide, to affected employees, medical attention inc luding follow-up examinations**  **which MEDFIRST or another approved medical office determines is ne cessary under the following**  **circumstances. a. whenever an employee develops signs and/or symptoms associate**  **d with a hazardous chemical to which they may have been exposed, the employee shall**  **be provided an opportunity to receive appropriate medical examination. The emp**  **loyee shall contact the Health and Safety Officer to initiate the medical program.**  **b. Where exposure monitoring reveals an exposure level routinely ab ove the OSHA action level**  **(AL) (or in the absence of an action level, exposure above the OSH A permissible exposure**  **level (PEL)) for OSHA regulated substances for which there a re medical monitoring**  **requirements, medical surveillance shall be established for tha t employee. Listed OSHA**  **standard medical surveillance requirements include the chemical be nzene, formaldehyde,**  **methylene chloride. c. Whenever an event takes place in the laboratory or work area suc**  **h as a spill, leak, explosion, or other occurrence resulting in the likelihood of a hazardous exposure,**  **the affected employee, laboratory or custodial, shall be provided an opportunity for**  **a medical consultation. This consultation is for the purpose of determining**  **the need for a medical examination.** **DEECO Health and Safety Plan Page 45 January 2010**

**All aspects of these examinations are provided by a licensed p hysician, or supervised by a licensed**  **physician. These examinations are provided without cost to the empl oyee, without loss of pay, and**  **at a reasonable time and place. The Health and Safety Officer who is also the Chemical Hygie**  **ne Officer will provide information to the physician:**  **1. Identity of the hazardous chemical to which the employee may have been exposed. 2. A description of the conditions of the exposure including exposure date if available**  **3. A description of the signs and symptoms of exposure that the employee is experiencing (if**  **any). The physician's written opinion shall include:**  **1. Recommendations for future medical follow-up 2. Results of examination and associated tests**  **3. Any medical condition revealed that may place the employee at inc reased risk as the result**  **of a chemical exposure. 4. A statement that the employee has been informed by the physic**  **ian of the results and told of any medical conditions that may require additional examination of treatment.** 

3.1 General Characteristics Routes of Entry **There are three major routes through which chemicals can enter the body and potentially cause harm.** 

Inhalation: **Contaminants in the air can be absorbed into the bloodstream dire ctly through the**  **lungs. In this manner, the contaminant can be carried to any organ in the body.** Ingestion: **Ingestion of chemicals may severely damage the tissues of the digestive tr act, damage**  **the stomach or other organs. The chemical can be absorbed into the bloodstream, or other body**  **fluids, and carried to other organs in the body.** Skin Absorption: **The skin can act as a protective barrier to many chemical agents. However, many**  **chemicals can penetrate the skin. In this manner, the chemicals can enter the bloodstream and be**  **distributed throughout the body. Wounds on the skin (e.g. cuts and abrasions) offer a di rect route**  **for chemicals to enter the bloodstream.** Physical Characteristics of Chemicals **Below are definitions of terms used in the following Chemical Sa fety Sections. Additional**  **definitions are located in the Guide to Common MSDS Terms, located in Appendix C. Gas - a formless fluid which takes the shape of its container.**  **Vapor - the gaseous form of a substance which is normally a solid or liquid a t room** 

**temperature. Fog - a visible, liquid aerosol.**  **Mist - a "fog" where the liquid particles are large enough to be individually s een.**  **Fume - particle formed by the condensation of vaporized solids. DEECO Health and Safety Plan Page 46 January 2010** 

**Dust - solid particles, capable of temporary suspension in air. Smoke - airborne particles generated from incomplete combustion process**  **es. Carcinogen - a substance capable of causing cancer in animals or humans.**  **Mutagen - a substance capable of changing the genetic material in a livi ng cell.**  **Fetotoxin - a substance capable of causing death or injury to fetus. Teratogen - a substance which can cause deformations in a fe**  **tus from exposure of a**

**pregnant female.**

Health Hazards **Substances to which field employees may be exposed have the potential to cause severe injury or**  **illnesses. The degree of injury or illness is a function of the exposure; that is the amount of the**  **substance and the time that an employee is in contact with it. Below are descriptions of various types**  **of health hazards that may exist when working with hazardous substances.**

Irritant: **Several chemicals may be an irritant to the skin, eyes, or respir atory tract. Irritation can**  **range from mild discomfort to severe and irreversible chemical burns on the skin or eyes. Examples**  **of irritants include ammonia, acids, bases, and several solvents.**

Sensitizer: **A chemical that is a sensitizer may not elicit a res ponse after one exposure. After**  **repeated exposures, however, a severe reaction may occur, not necess arily at the point of contact.**  **The reaction may be a skin rash, or in the case of toluene diisocya nate, failure of the respiratory**  **system, Examples of sensitizers are formaldehyde, poison ivy, potassium di chromate.** 

Narcotic: **Narcotics cause a depression of the central nervous system, pr oducing a sleepy or dizzy**  **effect. Narcotics may make an employee unable to perform his /her work. Other safety hazards arise**  **when employees affected by a narcotic attempt to continue to work. Most organic solvents can**  **produce narcotic effects.** Asphyxiant: **An asphyxiant reduces the amount of oxygen available for use by the body. This can**  **cause suffocation, leading to coma or even death. There are two typ es of asphyxiants. A Simple**  **Asphyxiant reduces the amount of oxygen in an area. Examples of simple asphyxiants include**  **carbon dioxide, nitrogen, argon, and other inert gases. A second type of asphyxiant is called a**  **Chemical Asphyxiant. A chemical asphyxiant enters the body thr ough the lungs, and competes with**  **oxygen for space in the red blood cells. With these asphyxiants, suffocation can occur even if there**  **is plenty of oxygen in the room. Examples of chemical asphyxia nts include carbon monoxide, and**  **cyanide gas.** Systemic Poison of Toxin: **A systemic poison or toxin is a substance that produces an af fect away**  **from the point of contact. For instance carbon tetrachloride can be inhaled or absorbed through the**  **skin, but exhibits its major effects upon the liver and kidneys. It is important to remember that different chemicals react**  **differently with the body. Several chemicals exhibit more than one effect. The employee must re**  **view the MSDS for the specific chemical he/she is working with to fully understand all of the potential hazards.** **DEECO Health and Safety Plan Page 47 January 2010**

3.2 Acids
Potential Hazards Routes of Entry - Inhalation, Ingestion, Contact **1. Acids are corrosive substances having a pH < 7.0. 2. Acid vapors and fumes can cause irritation of the eyes, skin, and respiratory trac**  **t. 3. Chemical burns on tissue can occur if acids are allowed to contact skin, eyes, or lung**  **s. 4. Severe gastrointestinal pain and tissue injury can occur if acids are inge**  **sted.** Symptoms of Overexposure **Hazards of exposure are mainly from acute (short duration) exposur es. Effects of acid fumes**  **or vapors include eye, throat, nose, or lung irritation. Skin or eye cont act with acids may**  **result in severe chemical burns.**

First Aid **In the event that acid comes in contact with your skin or eyes:** # **Proceed immediately to the nearest eyewash station. Call for assistance from a co**  **worker if necessary.** # **Flush the affected area with copious amounts of water for at least 15 minutes. If**  **contact was with eye, pull the eyelid up and out, exposing the corne a, while flushing**  **with water.** # **Notify the project manager or coordinator and seek medical attention. If acid is spilled on your clothing:**  # **Remove contaminated clothing immediately.** # **Flush skin area with water for 15 minutes.** # **Notify the manager or coordinator and seek medical attention. Personal Protective Equipment**  **1. Gloves (Disposable Latex or Nitrile) 2. Protective Clothing (Saranex Tyvek Suits)**  **3. Respiratory Protection - Minimum or a half-mask, air-purifying respirator with Acid Gas or**  **Organic Vapor/Acid Gas Cartridges. 4. Eyewear - Minimum of safety glasses with side shields.**  **Recommend chemical splash goggles.** 

3.3 Bases
Potential Hazards Routes of Entry - Inhalation, Ingestion, Contact **1. Bases are corrosive substances having a pH > 7.0. 2. Vapors and fumes generated from bases can cause irritation of**  **the eyes, skin, and respiratory tract.** **DEECO Health and Safety Plan Page 48 January 2010**

**3. Chemical burns can occur if bases are allowed to contact skin or eyes. Bases can cause**  **irreversible damage to the eyes, even in dilute concentrations. 4. Severe gastrointestinal pain and tissue injury can occur if bases are i**  **ngested.** Symptoms of Overexposure **Hazards of exposure are mainly from acute (short duration ) expo sures. Effects of alkali**  **fumes or vapors include eye, throat, nose, or long irritation. Skin or ey e contact with bases**  **may result in severe chemical burns.**

First Aid **In the event that a base comes in contact with your skin or eyes:** # **Proceed immediately to the nearest eyewash station. Call for assistance from a co**  **worker if necessary.** # **Flush the affected area with copious amounts of water for a t least 15 minutes. If**  **contact was with eye, pull the eyelid up and out, exposing the cornea.** # **Notify the project manager or coordinator and seek medical attention. If a base is spilled on your clothing:**  # **Remove contaminated clothing immediately.** # **Flush skin area with water for 15 minutes.** # **Notify the project manager or coordinator and seek medical attention.** Personal Protective Equipment **1. Gloves (Disposable Latex or Nitrile) 2. Protective Clothing (Saranex Tyvek Suits)**  **3. Respiratory Protection - Minimum or a half-mask, air-purifying respirator with Acid Gas or**  **Organic Vapor/Acid Gas Cartridges. 4. Eyewear - Minimum of safety glasses with side shields. Rec**  **ommend chemical splash goggles.**  3.4 Compressed Gases
Potential Hazards Routes of Entry - Inhalation, Contact **1. Cylinders may explode if heated above 135** E **F or dropped, damaging the valve stem. 2. Fire Hazards may exist if a Flammable Gas, Oxygen or ot**  **her oxidizing gas cylinder is placed near an open flame.**  **3 Skin and eye burns may result if direct contact with an escaping gas is made. 4. Suffocation can occur if the concentration of a gas is allowed**  **to decrease the percent of oxygen in an area.**  **5. If Oxygen is allowed to be released, it may be absorbed int o clothing and take as long as 15**  **minutes to disperse. This could lead to a flash clothing fire if the person comes in contact**  **with an ignition source. 6. Severe burns may result from skin or eye contact with cryogenic gases.** **DEECO Health and Safety Plan Page 49 January 2010**

**7. Prolonged breathing of oxygen can be toxic. 8. A fire or explosion hazard may exist when using nitrogen and helium**  **, since these gases can condense oxygen from the air, creating an oxygen-rich environment at t**  **he location of the gas.** Symptoms of Overexposure **Symptoms of overexposure to compressed gases depends on the specific gas. Ref er to the**  **MSDS of the gas for this information.** General Handling Procedures **1. Cylinders should be tagged with a FULL, IN USE, or EMPTY Status Tag at all t imes.**  **2. Cylinders must have the valve protection cap in place when being moved. 3. Cylinders shall be stored such that they are protected from ex**  **cessive heat or open flame (125**

E **F), physical shock, and electrical circuits. 4. Cylinders shall be secured using a chain or strap, to a wall, bench or other firm**  **support. 5. Never completely empty a gas cylinder.**  **6. Never use oil on regulator valves or connections. Oil can degrade the regulator diaphragm,**  **contaminate the gas, or be oxidized in air to form explosive products. 7. Use only CGA (Compressed Gas Association) approved regulators**  **and fittings for the specific gas being used. Do not mix a given regulator with different gases.**  **8. Do not tamper with manufacturer's safety devices or check valves. 9. Leak-test all fittings and connections using an appropriate leak-test solut**  **ion. 10. Jewelry should not be worn when handling or using cryogens.**  **11. If a cylinder should develop a leak:** # **Remove all sources of spark or flame.** # **Place in exhausted enclosure or remove to a safe outdoor area.** # **Identify the cylinder as "Leaking Cylinder". Notify the supplier.** # **For Flammable Gases, attach a control valve to the cylinder valve and allow the gas**  **to escape. Adjust to a moderate discharge rate. 12. If a cylinder containing cryogenic gases is dropped:**  # **Evacuate area within 100-ft radius of cylinder;** # **Keeping a safe distance (no less than 50 feet), determine if the cylinder's inner vessel**  **relief valve is venting, or if the outer vessel bursting disc ha s ruptured. If either is**  **venting gas, do not approach until there is no further discharge.** # **When emission from the cylinder has not been noticed for 15 minutes, car efully open**  **the vent valve and the gas withdrawal valve to empty the cylinder. Move away from**  **the cylinder after opening valves.** # **Once emptied, place in upright position. Write "Dropped Cylinde r" on the cylinder**  **status tag and notify the supplier.**

First Aid **If skin or eye contact occurs, flush area with unheated water and apply cold compresse s.** **DEECO Health and Safety Plan Page 50 January 2010**

Personal Protective Equipment **Safety glasses should be worn at a minimum. Cryogenic gloves shoul d be worn if contact with a**  **cryogenic gas is possible.** 3.5 Cryogenic Materials **Cryogenic materials are substances that are kept at very low tempera tures (less than 100**  E **F). Cryogenics may be liquids or solids. Atmospheric gases, such as**  **nitrogen, oxygen, or hydrogen, that are cooled to temperatures less than 150**  E **F become liquified and are examples of cryogenic materials. "Dry Ice" is another example of a super-cooled gas, carbon dioxi**  **de.**

Potential Hazards Routes of Entry - Contact, Inhalation **1. Severe burns may result from skin or eye contact with cryogenic materials**

**. 2. Some liquid gases can deplete the available oxygen in a room S**  **uffocation can result if not used in a well-ventilated area.**  **3. Prolonged breathing of pure oxygen may have harmful physiological effects**

**. 4. Nitrogen and helium can condense oxygen from the air, creating an oxy**  **gen-rich environment at the location of the gas. This could be a fire or explosion hazard.**  **5. Cryogenic gases are stored under high pressure. This creates the same potential hazards as**  **other compressed gases (see Section 3.4). 6. Hydrogen is extremely flammable and is a fire and explosion hazard.**  **7. Liquid oxygen, while not flammable itself, does increase the fla mmability of ordinary**  **combustibles.** General Handling Procedures **1. When there is the potential for contact with a cryogenic mate rial, a full face shield will be**  **required. In addition, a lab coat and gloves suitable for cold materi al handling shall be worn.**  **2. Jewelry should not be worn when handling or using cryogens. 3. When handling cryogens, trousers should not have cuff.**  **4. Use tongs to remove objects that are immersed in cryogenic li quids. Never use your hands,**  **even if wearing gloves!! 5. Use only in well-ventilated areas.**  **6. Store away from flammable and combustible materials. 7. Do not use near open flame or spark-producing equipment.**  Emergency Procedures **1. If skin or eye contact occurs, flush area with unheated water and a pply cold compresses.**  **Notify your supervisor and seek medical attention. 2. If a cylinder containing cryogenic gases is dropped:**  # **Evacuate area within 100-ft radius of cylinder; DEECO Health and Safety Plan Page 51 January 2010** 

# **Keeping a safe distance (no less than 50 feet), determine if the cylinder's inner vessel**  **relief valve is venting, or if the outer vessel bursting disc has ruptured. If either is**  **venting gas, do not approach until there is no further discharge.** # **When emission from the cylinder has not been noticed for 15 minutes, car efully open**  **the vent valve and the gust withdrawal valve to empty the cylinder. Move away from**  **the cylinder after opening valves.** # **Once emptied, place in upright position. Write "Dropped Cylinde r" on the cylinder**  **status tag and notify the supplier.** 3.6 Flammable Liquids and Gases
Potential Hazards Routes of Entry - Inhalation, Ingestion, Contact **1. Flammable liquids and gases pose significant fire and explosion hazards. 2. Many flammable liquids:**  # **Can be readily absorbed through the skin.** # **Can cause dermatitis.** # **Are systemic poisons once in the body. 3. Eye, skin and respiratory tract irritation may occur.**  **4. Many flammable liquids and gases can produce depression of the c entral nervous system**  **(decreases motor response, dizziness, etc.)** Systems of Overexposure **Symptoms of overexposure to flammable liquids and gases will de pend on the specific**  **substance. Refer to the MSDS of the chemical for this information.**

General Procedures **1. Keep flammable materials away from open flame, sparks, or excessi ve heat.**  **2. Keep away from oxidizing agents such as oxygen. 3. Store in chemical cabinet, isolated from other chemicals.**  **4. Keep combustible material such as wood, cloth, and paper out of storage cabinet s.**  **5. Do not leave containers of flammable materials in work areas overnight. Return all bottles**  **to the proper storage cabinet. 6. Flammable liquids and gases should be used only in well ventilated areas.** 

First Aid **1. If skin or eye contact occurs, flush affected area with water for 15 minutes. Remove**  **contaminated clothing. Seek medical attention. 2. In the event of a burn; extinguish flames by applying a fire blanket, or roll**  **ing on the floor. Do not attempt to fan out the flames.**  **3. Use only an approved fire extinguisher to extinguish flames. Do not use water on flammable**  **liquid fires. Pouring water on these fires may only spread the flames over a wider area.** **DEECO Health and Safety Plan Page 52 January 2010**

Personal Protective Equipment **1. Gloves (Disposable Latex or Nitrile) 2. Eyewear - minimum of safety glasses with side shields. Che**  **mical goggles required if there is a potential for splash.**  3.7 Organic Solvents
Potential Hazards Routes of Entry - Inhalation, Ingestion, Contact **1. Solvents can cause skin, eye and respiratory tract irritation. 2. Solvents may cause defatting of the skin, which lessens the abi**  **lity of the skin to protect against other chemicals.**  **3. Some solvents are also systemic toxins and can produce effects on the liver, kidneys, and**  **other organs if allowed to be absorbed through the skin. 4. Inhalation of solvent vapors may produce narcotic or anesthetic effe**  **cts, and depression of the central nervous system.**  **5. Many organic solvents are also flammable.** Symptoms of Overexposure **Symptoms of overexposure to solvents will depend on the specific su bstance. Refer to the**  **MSDS of the chemical for this information.**

General Procedures **1. Use solvents only in local exhaust hood or well ventilated areas. 2. Do not continue to work if you feel dizzy or sleepy. Have a co-worke**  **r secure your apparatus (turn off heat, close containers, etc.) and escort you away from the area.** 

First Aid **1. If skin or eye contact occurs, flush affected area with water for 15 minutes. Remove affected**  **clothing. 2. If dizziness occurs from inhalation, get to fresh air.**  **3. In the event of a spill:** # **Turn off all sources of flame or sparks. Keep area well ventilated.** # **Small spills can be handled by using a solvent spill kit. 4. Use only an approved fire extinguisher to extinguish flames. D**  **o not use water on liquid fires. Pouring water on these fires may only spread the flames over a wider are**  **a.** Personal Protective Equipment **1. Gloves (Disposable Latex or Nitrile) 2. Eyewear - minimum of safety glasses with side shields. Che**  **mical goggles required if there is a potential for splash.** **DEECO Health and Safety Plan Page 53 January 2010**

3.8 Oxidizing Agents
Potential Hazards Routes of Entry - Inhalation, Ingestion, Contact **1. Oxidizing agents can be irritating to skin, eyes, and the respiratory trac t.**  **2. Most oxidizing agents are highly reactive, and may react violentl y with metals, as well as**  **other chemicals. 3. Oxidizers are corrosive and can cause burns on skin and eyes.**  **4. Oxidizers spontaneously evolve oxygen, and therefore may create a fire on explosion hazard**  **in some environments.** Symptoms of Overexposure **Symptoms of overexposure to solvents will depend on the specific sub stance. Refer to the**  **MSDS of the chemical for this information.**

General Procedures **1. Do not mix with organic solvents. 2. Always store in unbreakable, inert containers.**  **3. Do not use cork or rubber stoppers. 4. Respiratory protection is required when handling chlorine or bromine gas.**  **5. Label containers of oxidizers with the date received, and the date the container was first**  **opened.**

First Aid **1. If skin or eye contact occurs, flush affected area with water for 15 minutes. Remove affected**  **clothing. 2. In the event of a spill:**  # **Turn off all spark and open flame sources.** # **Cover spill area with a bisulfite solution. Mix well and spra y with water. Place**  **waste in container with water. 3. If a gas leak occurs, remove all sources of spark or flame.**  **Place cylinder in an exhausted enclosure or remove it to a safe outdoor area as soon as possible.**  Personal Protective Equipment **1. Gloves (Disposable Latex or Nitrile) 2. Eyewear - minimum of safety glasses with side shields. Che**  **mical goggles required if there is a potential for splash.** 

3.9 Asbestos Awareness **Asbestos is the name applied to six naturally occurring minera ls that are mined from the earth.**  **Because it is so hard to destroy asbestos fibers, the body cannot break the m down or remove them**  **once they are lodged in lung or body tissues. They remain in place where they can caus e disease.**  **There are three primary diseases associated with asbestos exposure: Asbestosis**  **Lung Cancer Mesothelioma** **DEECO Health and Safety Plan Page 54 January 2010**

**DEECO personnel may be exposed to asbestos while on a client's premises. The most common use**  **of asbestos at our client’s facilities is insulation on pipe s and vessels. Asbestos boiler insulation**  **does not present a hazard unless the protective covering is c ut or damaged in such a way that the**  **asbestos underneath is actually exposed to the air. The project manager/field team leader will ensure**  **that the client has identified or provided means to identify asbestos-containing e quipment.**  **If you do not know whether something is asbestos or not, assume that i t is until it is verified**  **otherwise.**

**DO NOT DISTURB IT. Never...**  **Drill Hammer**  **Cut Saw**  **Break Damage**  **Move Disturb**  **...any asbestos-containing materials or suspected materials.**

3.10 Benzene Awareness **Benzene is a volatile chemical formed from both natural processe s and human activities. Natural**  **sources of benzene include emissions from volcanoes and forest fires. Benzene is also a natural part**  **of crude oil, gasoline, and cigarette smoke. Benzene is widely used i n the United States, ranking in**  **the top 20 chemicals for production volume. It is primarily used as a solvent, as a starting material**  **for the production of other chemicals, and as a gasoline additive. Brea thing benzene can cause**  **drowsiness, dizziness, and unconsciousness; long-term benzene exposure ca uses effects on the bone**  **marrow and can cause anemia and leukemia. The Occupational Safety and Health Administration**  **(OSHA) recognizes benzene as a hazardous material and imposes strict exposure limits in the**  **workplace. It is unlikely that DEECO personnel would be exposed to benzene on a**  **client's premises at levels above the OSHA permissible exposure limits (1 ppm TWA for 8**  **hour and 5 ppm STEL for 15 minutes). If the potential for benzene exposure exists, the proje**  **ct manager/field team leader will ensure that the client has identified regulated areas where the**  **permissible exposure limits could be exceeded.**  **DEECO does not use benzene for any sample recovery procedures.** 3.11 Hydrogen Sulfide Awareness **Hydrogen sulfide (H 2**  **S) is a colorless gas with a powerful nauseating smell of rot ten eggs. The odor**  **is a poor warning property because hydrogen sulfide exposure quickly dea dens the sense of smell.**  **The gas is heavier than air and may collect in low areas such a s sewers, pits, tunnels or gullies. High**  **airborne levels of hydrogen sulfide (between 4.3 and 46.0 percent of gas by volume in the air) may**  **catch fire if there is a source of ignition. If the gas is burned, toxic p roducts such as sulfur dioxide** **DEECO Health and Safety Plan Page 55 January 2010**

**will be formed. Hydrogen sulfide is incompatible with oxidizing a gents, such as nitric acid and**  **chlorine trifluoride, and may react violently or ignite spontaneously. Hydrogen sulfide is extremely toxic. It may cause death instant**  **aneously in high airborne concentrations. Low levels may be extremely irritating to the lungs, nose, throa**  **t and eyes. Hydrogen sulfide can be detected by smell at levels as low as**  **0.13 parts hydrogen sulfide per million parts air (ppm). Odor cannot be used as a warning because the ga**  **s can deaden the sense of smell within 2 to 15 minutes in exposures of approximately 100 ppm. A single**  **breath of hydrogen sulfide at about 1000 ppm may paralyze the respiratory system and resul**  **t in coma and death. Convulsions may also occur. Prolonged exposure at about 250 ppm hydrogen sulfide may cause t**  **he lung tissue to swell and fill up with water (pulmonary edema).**  **This effect may occur after the exposed worker recovers from t he irritant effects of the gas.**  **Exposures of 20 to 50 ppm hydrogen sulfide for one hour may cause inflamma tion of the cornea and**  **the delicate lining of the eye and eyelid (a condition called kerat oconjunctivitis). Exposures for long**  **periods at 50 ppm may cause severe irritation of the nose, throat and lungs. Workers exposed to**  **lower concentrations of hydrogen sulfide may develop headaches, eye disorders and chronic**  **bronchitis. DEECO personal may be exposed to hydrogen en sulfide on a client's**  **premises at levels above the OSHA permissible exposure limits (20 ppm (ceiling) with the**  **following exception: if no other measurable exposure occurs during the 8-hour work shift, exposures may**  **exceed 20 ppm, but not more than 50 ppm (peak), for a single time period up to 10 minutes.).**  **Small amounts of hydrogen sulfide occur in crude petroleum but natural gas can contain up to 90%**  **. By far the largest industrial route to H**  **2 S occurs in petroleum refineries. Other sources of hydrogen sulfide**  **include coke ovens, paper mills (using the sulfate method), and tanneries. H**  **2 S arises from virtually anywhere where**  **elemental sulfur comes into contact with organic material, especially at high temperatures.**  **Should the potential exist for exposure to H 2**  **S, the project manager/field team leader will work with the client to ensure that all personnel are provided with the following training;**  **1. Identification of the characteristics, sources, and hazards of Hydrogen Sulfide, 2. Proper use of the Hydrogen Sulfide detection methods used on the site,**  **3. Recognition of, and proper response to, Hydrogen Sulfide warnings at the workplac e,**  **4. Symptoms of Hydrogen Sulfide exposure, 5. Proper rescue techniques and first-aid procedures to be used in a**  **Hydrogen Sulfide exposure, 6. Proper use and maintenance of personal protective equipment. Demons**  **trated proficiency in using PPE should be required,**  **7. Worker awareness and understanding of workplace practices and mai ntenance procedures**  **to protect personnel from exposure to hydrogen sulfide, 8. Wind direction awareness and routes of egress,**  **9. Confined space and enclosed facility entry procedures. 10. Locations and use of safety equipment,**  **11. Locations of safe briefing areas, 12. Use and operation of all Hydrogen Sulfide monitoring systems, and**  **13. Emergency response procedures, corrective action, and shutdown procedures. DEECO Health and Safety Plan Page 56 January 2010** 

**At most client facilities where hydrogen sulfide exposure coul d occur, this training is required by**  **the client prior to entry.**

3.12 Lead Awareness **Lead is a toxic metal that was used for many years in products found in and around our homes. Lead**  **also can be emitted into the air from motor vehicles and industria l sources, and lead can enter**  **drinking water from plumbing materials. Lead may cause a range of health effects, from behavioral**  **problems and learning disabilities, to seizures and death. Childre n six years old and under are most**  **at risk. Most Common Sources of Lead Poisoning:**  **1. Deteriorating lead-based paint, 2. Lead contaminated dust, and**  **3. Lead contaminated residential soil DEECO personal may be exposed to lead hazards created by renova**  **tion, repair and painting (RRP) activities at client facilities that disturb lead-based pa**  **int. The lead exposure limit is fifty micrograms per cubic meter of air (50 ug/m**  **3 ) averaged over an 8-hour period. The project manager/field team**  **leader will ensure that the client has identified any areas wh ere the potential for exposure to lead**  **exists and access these areas by DEECO employees will be prohibi ted.** **DEECO Health and Safety Plan Page 57 January 2010**



### 4.0 Hazard Communication Requirements

Introduction **The Occupational Safety and Health Administration's (OSHA) Ha zard Communication Regulation**  **(29 CFR 1910.1200) requires that employees be informed of all hazardous che micals located in their**  **workplace. This program will describe how DEECO intends to protect the safe**  **ty and health of our employees who are exposed to hazardous chemicals in the workplace, and to compl**  **y with the provisions of 29 CFR 1910.1200.**  **Each supervisor will be held responsible for strict adherence to these policies and will closely**  **monitor all activities involving hazardous chemicals. Each employee will carefully follow established work practic**  **es and promptly report observed or potential problems to supervision.**  **There is no job at DEECO so vital or urgent as to justify the risk of employee overexposure to a**  **hazardous chemical. Ask when in doubt. Proceed with a job only afte r being satisfied that it is safe**  **for you to do so. A list of all hazardous chemicals for each workplace has been made and is re**  **adily available, upon request, to any employee, working on any shift. It is located in eac**  **h tow vehicle, shop area, and wet chemistry lab.**  **DEECO is responsible to ensure that the list of hazardous chemic als is kept current and that a current**  **MSDS for each hazardous chemical used is on hand. A chemical that is not shown on the curre nt**  **list will not be ordered without prior coordination with the wet chemistry lab m anager.**  **All containers of hazardous chemicals in each workplace will be conspicuously labeled with the**  **identity of the chemical, and the appropriate hazard warnings. I f the chemical is a known or**  **suspected carcinogen, or it is known to affect a specific organ of the body, this information will also**  **be placed on the container label. The person having supervisory re sponsibility for the storage or use**  **or each hazardous chemical will ensure that such labels are not de faced and that they remain legible**  **at all times. The health and safety officer will ensure that an adequate supply of labels are on hand**  **and made available to the responsible supervisors. When an outside contractor is used, it will be the responsibility**  **of the project manager to advise the contractor of any hazardous chemical to which their employees may**  **be exposed and the appropriate protective measures to be taken. This procedure also works conversely.**  **All employees exposed to any hazardous chemicals will complet e an information and training**  **program which includes at least the subjects listed below. New employee s must complete similar**  **instructions before initial exposure to any hazardous chemical in the workplac e.** **DEECO Health and Safety Plan Page 58 January 2010**

**Adequate training of all employees exposed to hazardous chemicals will be given by the Health and**  **Safety Officer or an approved training instructor and assisted as needed by the Hazard**  **Communication Program Monitor. Employee information for this program will include:**  **1. The purpose and need for such a program, including the basic concept that gives every employee**  **the right to know about hazardous chemicals with which they work. 2. The location and availability of the written Hazard Communicati**  **on Program, plus the list of hazardous chemicals and their corresponding MSDS's.**  **3. The identity upon request, of any chemical to which the emp loyee id exposed. In the case of a**  **trade secret chemical, the name on the MSDS will be provided. Employee training shall include at least the following:**  **1. Methods and observations used to detect the presence or release of a hazardous chemical in the**  **work ares such as monitoring devices, appearance, or odor. 2. The physical and health hazards associated with each chemical, as specifie**  **d in the MSDS. 3. Action that employees can take to protect their own safety and**  **health, including specific procedures that have been established for normal work practices, e**  **mergency procedures, and policies on the use of personal protective equipment.**  **4. Details of the Hazard Communication Program, including an explanat ion of the labeling system**  **used on in-house containers of hazardous chemicals. Also, details of how e mployees can obtain and**  **use information contained in the MSDS. It is the intent of DEECO management to protect the safety a**  **nd health of each employee, our most valuable and valued asset. By following correct procedures, no employ**  **ee should experience and harmful effects from working with chemicals in their workplace.**  Client Responsibilities **Clients are required to inform DEECO personnel working on the premi ses of all hazards located in**  **the area. In addition to chemical hazards, the client should inform DEECO:** # **Location of all emergency exits.** # **Location of nearest medical facilities.** # **Location of nearest emergency equipment (fire extinguishers, sa fety showers,**  **eyewashes, etc.) The client should have available for DEECO personnel MSDSs on al**  **l chemicals located in the area(s) where DEECO will be performing work.**  **The team leader should ensure that the above information is obtained before s etting up equipment**  **to perform the work. DEECO Health and Safety Plan Page 59 January 2010** 

DEECO Responsibilities **DEECO is required to inform its employees of all hazards that they may contact. MSDSs for each**  **chemical used by the Field Division are available in the centra l MSDS file located at the field office.**  **DEECO must also supply the client, upon request, information on the chemicals which DEECO**  **brings on the client's premises to perform field work. MSDS s are present prior to entering the**  **client's premises.** Written Program **The OSHA regulation requires that DEECO have a written Hazard Communication Program. The**  **written program for the Field Division is located in Appendix D of this Health and S afety Plan.**  4.1 Material Safety Data Sheets **The manufactured or distributor of chemicals used by DEECO is required to supply DEECO with**  **a MSDS. Employees must be informed of the information on the MSDS prior to working with a**  **chemical. A MSDS must exist for all hazardous chemicals. MSDSs for che**  **micals used on a client's site must be available for review or photocopying by the client. A lis**  **t of all chemicals brought on site by DEECO should be supplied to the client. The client should be informed that a MSDS**  **is available for each chemical on that list.**  **Hazardous materials that require a MSDS are substances whic h may present a physical or health**  **hazard. A material presents a** Physical Hazard **if it is:** # **Flammable** # **Combustible** # **Explosive** # **Reactive** # **Under Pressure A material presents a**  Health Hazard **if it is:** # **Corrosive** # **An Irritant** # **A Sensitizer** # **A Carcinogen** # **Harmful to body organs, including skin, eyes, reproductive organs, liver , kidneys,**  **lungs, blood, or nervous system. Each MSDS is required to provide the user with the following information:** 

Section I **- Supplier Information. This section must include the manufacturer 's name, address, and**  **an emergency telephone number. Also included in Section I is the nam e of the chemical as it appears**  **on the chemical label. Synonyms for the chemical name may also be given. DEECO Health and Safety Plan Page 60 January 2010** 

Section II **- Hazardous Ingredients Information. This section will list all the hazardous ingredients**  **of the chemical if they constitute 1% of the mixture or more. If the hazardous ingredient is a**  **carcinogen (capable of causing cancer), the ingredient will be listed if it constitutes 0.1% of the**  **mixture or more. Also listed for each ingredient will be the p ercentage that it makes up of the**  **mixture, and its current permissible exposure level (PEL).**

Section III **- Physical/Chemical Characteristics. This section will l ist characteristics such as boiling**  **point, vapor pressure, specific gravity, melting point, vapor densit y, evaporation rate, and solubility**  **in water. The substance's appearance and odor characteristics will also b e given.** 

Section IV **- Fire and Explosion Hazard Data. Included in this section will be the chemical's flash**  **point, flammability limits (upper and lower), the correct typ e of material to use to extinguish a fire,**  **any unusual fire and explosion hazards, and any special fire fighting procedures.**

Section V **- Reactivity Data. This section will list any conditions that should b e avoided with this**  **chemical, whether or not the chemical is stable, substances the chemical is incompatible with, any**  **hazardous decomposition products or any hazardous polymerization that may occur.**

Section VI **- Health Hazard Data. Information included in this section will be possible routes of**  **exposure, signs and symptoms of overexposure (both acute and chromic exposures), medical**  **conditions that may be aggravated by exposure to this chemical, and emergency first aid.** 

Section VII **- Precautions for Safe Handling. This section will list step s to be taken in the event of**  **a spill or release of the chemical, the proper waste dispos al methods, and any precautions that should**  **be taken during handling and storage.**

Section VIII **- Control Measures. Included in this section will be the proper personal protective**  **equipment (respiratory protection, gloves, eye/face protection), t he required ventilation system, and**  **other work practices that should be followed when using this chemical.**

Section IX - **Additional Information. This section will list any other pertinent information such as**  **transportation requirements or where to get other information regarding the chemi cal.**  4.2 Chemical Labelling **All chemicals used in the field or at DEECO must be labelle d. Chemical containers received from**  **the manufacturer are required to contain the chemical's name, hazar d warnings, and the**  **manufacture's name and address. This manufacturer's label may not be defaced in any manner.**  **Beakers and other containers used by DEECO employees must also b e clearly labelled with the**  **chemical name at all times. Several chemical manufacturers place the NFPA (National Fir**  **e Protection Association) hazard label on the bottle. This label identifies some of the hazardous properties of the che**  **mical. Transfer containers used by more than one employee must be label**  **led. Chemical formulas must not be used (for example, use "Acetone" instead of CH**  **3 COCH**  **3 ).** **DEECO Health and Safety Plan Page 61 January 2010**

4.3 Employee Exposure Monitoring **In order to ensure that field personnel are not overexposed to hazar dous materials, the DEECO**  **Safety Officer may direct the Project Manager or Coordinator to perform employee exposure**  **monitoring. Results from monitoring surveys will be forwarded to the departme**  **nt managers. The manager must review the report with each employee in the department. This c**  **an be accomplished by reviewing the report in a department meeting or circulating the report t**  **o all employees. Employees must sign an Employee Notification Form which accompanies the report. The**  **employees' signatures indicate that the report was reviewed and understood by each employee. The de**  **cision to monitor employee exposure will be made on a project-by-project basis by the DEE**  **CO S.O. and the Project Manager or Coordinator.**  **The department managers must retain copies of all monitori ng reports. These reports should be**  **reviewed with all new employees, or employees being reassigne d to the area, before allowing the**  **employee to work in the area. Employees may review past sampling reports that are repr**  **esentative of their exposure by contacting their department manager, the Director of Personnel, or the DEECO S.O.**  4.4 Employee Medical Surveillance **DEECO requires each employee to take a pre-employment physical. This physical establishes the**  **employee's physical condition before performing work at DEECO. In addition, DEECO field**  **employees will receive annual physicals based upon their job descrip tion and age.**  **Employees may receive additional medical evaluation if:** # **Signs or symptoms associated with exposure to a hazardous chemica l at DEECO**  **develop.** # **Routine exposure monitoring indicate that employee exposure exceeds the**  **Permissible Exposure Level or Action Level for a given substance.** # **A spill, leak or other event occurs which may have resulted in exp osure to a**  **hazardous exposure. These physicals will be provided during normal working hours (when poss**  **ible) and at no cost to employees. Copies of all medical evaluations will be forwar**  **ded to the Director of Personnel for placement in the employee's confidential, personal file. Physic**  **al evaluations made under the above conditions shall not reveal findings of diagnoses unrelated to the employ**  **ee's occupational exposure. Employees may at any time, review all medical information on f**  **ile by contacting either the department manager or the Director of Personnel.**  4.5 Employee Access to Records **Employees may be asked to participate in chemical exposure monitoring. DEECO will maintain**  **records of employee medical surveillance, exposure monitoring, and oc cupational accidents or**  **injuries. As per OSHA regulations, this information may be re viewed by employees by requesting** **DEECO Health and Safety Plan Page 62 January 2010**

**the information from the Area Supervisor, Manager or the Personnel Director. A copy of the OSHA**  **standard regarding access to exposure and medical records may be obtained from the DEECO S.O.**  **Responsibilities The DEECO Safety Officer must ensure that:**  # **All employee exposure monitoring reports are reviewed by emp loyees, and that**  **employees acknowledge the receipt of the reports by signing the report.** # **Copies of the signed report are sent to the Personnel Director.** # **Other information, such as MSDSs, ventilation records, etc. are mai ntained for at**  **least 30 years. The Personnel Director must ensure that:**  # **Employee medical, exposure and accident/injury records are maint ained for the**  **length of employment plus thirty (30) years.** # **A response to any internal and external requests for medical or exposure records is**  **given within 15 working days. The Department Managers must ensure that:**  # **Employees review and sign all Employee Exposure reports.** # **Employees are advised of the right to access medical and exposur e records annually**  **in a department safety meeting. DEECO Health and Safety Plan Page 63 January 2010** 



### 5.0 Personal Protective Equipment **The procedures and guidelines detailed in the following sections are to be used by DEECO Field**  **personnel while performing work on either DEECO or client premis es. If the client has additional**  **requirements for personal protective equipment, field personnel are to follow the procedures which**  **are more stringent. In all cases, all OSHA and/or EPA require ments are to be met. Field personnel**  **are not to use personal protective equipment for which they have not r eceived adequate training in**  **their use and limitations. Protective equipment, including personal protective equipment for eye**  **s, face, head, and extremities, protective clothing, respiratory devices, and protective shields and**  **barriers, will be provided, used, and maintained in a sanitary and reliable condition wherever it is**  **necessary by reason of hazards of processes or environment, chemical hazards, radiological hazards, or m**  **echanical irritants encountered in a manner capable of causing injury or impairment i**  **n the function of any part of the body through absorption, inhalation or physical contact.**  **Where employees provide their own protective equipment, DEECO wil l be responsible to assure its**  **adequacy, including proper maintenance, and sanitation of such equipment. All personal protective equipment shall be of safe design and c**  **onstruction for the work to be performed. The protective equipment, including personal protective**  **equipment (PPE) will be provided by DEECO at no cost to employees. DEECO will pay for**  **replacement PPE, except when the employee has lost or intentionally damaged the PPE.**  5.1 Respiratory Protection **Detailed information regarding the use of specific respirators is located in the DEECO Field Division**  **Written Protection Program.**

Use **Only employees that have been trained in the use of respiratory protection shall select or wear**  **respirators. Employees must:** # **Be fit-tested and trained annually.** # **Ensure that equipment is clean, available, and in good repair.** # **Use equipment only as instructed.** # **Receive medical clearance to wear a respirator.** # **Not have beards, long side-burns, or other conditions that may preclude a good face**  **to-facepiece seal.** # **Ensure that the proper respirator cartridge or canister i s used for a particular**  **contaminant. All cartridges are marked and color-coded. When donning the respirator:**  # **Place mask on face with chin in chin-cup.** # **Attach lower straps around neck.** # **Place top straps on crown of head, above ears.** # **Tighten all straps. DEECO Health and Safety Plan Page 64 January 2010** 

**Each time the respirator is conned, positive and negative pressure fit-chec ks must be performed.**  **Positive Pressure Fit-Checks:** # **Place the palm of hand over the exhalation valve.** # **Exhale gently. The mask should lift off the face without allowing the air to escape.**  **Negative Pressure Fit-Checks:** # **Cover the inlets of the cartridges with hands.** # **Inhale gently. The mask should collapse around the face without letti ng air in around**  **the face-to- respirator seal.**

Selection **Respirators provide specific Protection Factors based on the type to res pirator and the cartridge or**  **canister in use. The Protection Factor is defined as the concentra tion of an air contaminant outside**  **the mask divided by the concentration of that some contaminant inside the mask. For example, the**  **half-mask respirator with HEPA (High Efficiency Particula te Absolute) filter cartridge has a**  **Protection Factor of 10. This indicates that if worn in an area with a concentra tion of 0.05 mg/m**  **3 of airborne lead, the employee would actually be exposed to 0.005 mg/m**  **3 of lead.**  **Employees should select the type of respirator and cartridge ba sed on the decision criteria located**  **in the DEECO Respiratory Protection written program.** Inspection **Employees must inspect each respirator prior to donning. Straps , inhalation and exhalation valves,**  **cartridge gaskets, and facepiece should be inspected to ensure al l parts are present, clean and in good**  **condition.**

Decontamination **Respirator should be cleaned after each use. Remove cartridges and place the m in a plastic bag.**  **Wash respirator with warm, soapy water. Rinse the respirator thoroughly since soap can be a skin**  **irritant. Allow respirator to air dry. Place in plastic bag when dry and store in dry location away**  **from excessive heat. Do not place anything on top of respirator since this may distort the facepiece.**  Breathing Air Quality and Use **When DEECO employees are required to use atmosphere-supplying r espirators (supplied-air and**  **SCBA), DEECO will ensure that compressed air, compressed oxyg en, liquid air, and liquid oxygen**  **used for respiration accords with the following specifications: 1. Compressed and liquid oxygen shall meet the United States Pharma**  **copoeia requirements for medical or breathing oxygen;**  **2. Compressed breathing air shall meet at least the requireme nts for Grade D breathing air**  **described in ANSI/Compressed Gas Association Commodity Specificati on for Air, G-7.1-**  **1989, to include and oxygen content (v/v) of 19.5-23.5%, a hydrocarbon (condensed) content of 5 milligrams per cubic meter of air or less, a carbon m**  **onoxide (CO) content of 10 ppm or less; a carbon dioxide content of 1,000 ppm or less; and lack of noticeable odor.** **DEECO Health and Safety Plan Page 65 January 2010**

**DEECO will ensure that compressed oxygen is not used in atmosphe re-supplying respirators that**  **have previously used compressed air and ensure that oxygen concentrati ons greater than 23.5% are**  **used only in equipment designed for oxygen service or distribution. DEECO will ensure that cylinders used to supply breathing air**  **to respirators meet the following requirements:**  **1. Cylinders are tested and maintained as prescribed in the Ship ping Container Specification**  **Regulations of the Department of Transportation (49 CFR part 173 and part 178); 2. Cylinders of purchased breathing air have a certificate of ana**  **lysis from the supplier that the breathing air meets the requirements for Grade D breathing air; and**  **3. The moisture content in the cylinder does not exceed a dew point of - 50 deg.F (-45.6 deg.C)**  **at 1 atmosphere pressure. DEECO will ensure that compressors used to supply breathing ai**  **r to respirators are constructed and situated so as to:**  **1. Prevent entry of contaminated air into the air-supply system; 2. Minimize moisture content so that the dew point at 1 atmosphere**  **pressure is 10 degrees F (5.56 deg.C) below the ambient temperature;**  **3. Have suitable in-line air-purifying sorbent beds and filters to further ensure breathing air**  **quality. Sorbent beds and filters shall be maintained and replace d or refurbished periodically**  **following the manufacturer's instructions; 4. Have a tag containing the most recent change date and the signatur**  **e of the person authorized by the employer to perform the change. The tag shall be maintained at the comp**  **ressor. For compressors that are not oil-lubricated, the DEECO will e**  **nsure that carbon monoxide levels in the breathing air do not exceed 10 ppm.**  **For oil-lubricated compressors, the DEECO will use a high-tem perature or carbon monoxide alarm,**  **or both, to monitor carbon monoxide levels. If only high-temperature ala rms are used, the air supply**  **shall be monitored at intervals sufficient to prevent carbon monox ide in the breathing air from**  **exceeding 10 ppm. The DEECO will ensure that breathing air couplings are incomp**  **atible with outlets for non-respirable work site air or other gas systems. No asphyxiating substance**  **shall be introduced into breathing air lines.**  **DEECO will use breathing gas containers marked in accordance wi th the NIOSH respirator**  **certification standard, 42 CFR part 84. DEECO Health and Safety Plan Page 66 January 2010** 

5.2 Gloves
Use & Selection **Gloves should be worn when there is a potential for skin contact, suc h as pouring chemicals,**  **washing glassware with solvents, collecting samples, etc. Dif ferent gloves protect against different**  **chemicals. The glove compatibility chart below should be consulted when selec ting gloves.**  Inspection **Employees must check the gloves before donning by:** # **Inspecting for cracks, holes, or tears.** # **Performing a leak test by grasping the cuff of the glove quic kly such that air is**  **trapped inside the glove. Squeeze the glove to ensure that air ca nnot escape. If a**  **glove has any hole, crack, or tear, or has evidence of degradation to the material,**  **discard the glove. Employees must ensure that an ample supply of the proper glove**  **s are always available in the field.**

Decontamination **Employees should rinse gloves with water before removing. Gloves s hould be turned inside-out**  **during removal. Contaminated gloves are to be discarded.**

Glove Selection Chart Chemical(s) Glove Type **Solvents Nitrile (Sol-Vex) -Chlorinated PVA**  **Acids, Bases Nitrile (Sol-Vex)**

**Neoprene (Stanzoil) PVC Coated**  **Sample Collection Disposible Latex** 5.3 Protective Eyewear
Use & Selection **Chemical and physical hazards in the field have the potential to p roduce injuries to the eye and face.**  **These injuries could seriously impair or destroy vision, or permane ntly destroy facial skin. DEECO**  **provides eye and face protective equipment to employees at no cost. It is the responsibility of the Field Coordinator and Field Employees to ensure tha**  **t proper eye and face protection is available and worn in the work area. Contact**  **lenses may not be worn in areas requiring safety glasses.** **DEECO Health and Safety Plan Page 67 January 2010** Eyewear Hazards **Safety Glasses To be worn at all times on the work site or in designated "Eye** 

**Protection Required" areas. Safety Goggles To be worn whenever there is a potential of a che**  **mical splash**

**(e.g. handling or pouring solvents.) Face Shields To be worn when handling or pouring acids, bases, or other** 

**corrosive chemicals; when there is a potential of flying debris from drilling, cutting or grinding materials with power tools.**  Inspection **All safety glasses must meet the American National Standar ds Institute (ANSI) Standard Z87.1.**  **Safety glasses are required to have "Z87.1" stamped on the inside of the frame, or etched on the**  **lenses. DEECO will provide prescription safety glasses to those employees that require corrective**  **lenses. Safety glasses, goggles, or face shields that show visible si**  **gns of deterioration or damage should be repaired or discarded. If a damaged item is to be repaired, i**  **t should be placed in a plastic bag, sealed, and labeled "DAMAGED EQUIPMENT: FOR REPAIR".** 

Decontamination **All safety eyewear should be thoroughly cleaned with soap and wate r after each use in a**  **contaminated, or potentially contaminated, area.** 5.4 Protective Clothing **In many work situations it may be necessary for field personnel to wear full body protective clothing.**  **The Project Manager or Coordinator should identify the types of pr otective clothing that may be**  **necessary for a particular project, and ensure that the equipme nt is available at the work site. Brief**  **descriptions of the various protective clothing materials are given be low. In most situations, only**  **Tyvek or Saranex clothing will be necessary.** Standard Tyvek (non-porous) **Non-woven, olefin fiber fabric. Suitable for protection against m ost dusts, mists, and fumes.**  **Fabric melts at temperatures above 270** E **F. Should not be used to protect against solvent vapors or acid gases/fumes.**  Saranex Tyvek **Standard Tyvek which has one side coated with saranex plastic. This gives the clothing a**  **high level of resistance to most hazardous chemicals, including PCBs . Should not be used**  **in temperatures above 270** E **F. DEECO Health and Safety Plan Page 68 January 2010** 

Polyethylene Coated Tyvek **Standard Tyvek which has one side coated with polyethylene. This gives the clothing a high**  **level of resistance to most hazardous chemicals, including PCBs. M ore resistent to moisture,**  **and will protect individuals against chemical spills and spla shes better than the Saranex**  **Tyvek. Should not be used in temperatures above 270** E **F. Protective clothing is available in other materials, such as pol**  **yvinyl chloride, neoprene, Viton, and butyl rubber. These materials protect against a higher degr**  **ee of hazard than Field personnel would be expected to encounter. If the Project Manager or Coordinator f**  **eels that additional protection is required for a specific project, he/she should discuss clothing options with the S**  **.O.**

5.5 OSHA Levels of Protection
Use & Selection **Employees should select the level of personal protective equipment required for each individual**  **work site based on the current EPA guidelines below. Employees are not to perform tasks in the**  **work area if the proper personal protective equipment is not ava ilable or in good working condition.**  **At a minimum, employees must wear safety glasses and safet y shoes/boots at all work sites. DEECO**  **employees will not enter areas requiring Level A or Level B protection. All employees will be**  **trained on the proper use of protection equipment for Level C and Level D protect ion.** 

Levels of Protection **Level A - Highest level of respiratory, skin and eye protection is needed. Criteria inc**  **lude:**

# **High concentration of vapors, gases or particulates.** # **High potential for splash, immersion or potential exposure to hi ghly toxic**  **materials.** # **Confined or poorly-ventilated areas. Equipment:**  # **Supplied air respirator (pressure-demand SCBA or airline re spirator with** 

**escape bottle)** # **Fully encapsulating chemical resistent suit** # **Inner gloves, chemical resistent** # **Chemical resistent safety (steel-toe and shank) boots Optional Equipment includes coveralls, long cotton underwear, hard hat, disp**  **osable gloves and boot covers, cooling unit, 2-way radios.**  **Level B - Highest level of respiratory protection, lesser level of skin protecti**  **on. Criteria include:**

# **Atmospheres immediately dangerous to life and health (IDLH)** # **Oxygen deficient atmosphere (<20%).** # **Low potential for splash, immersion or potential exposure to highl y toxic**  **materials. DEECO Health and Safety Plan Page 69 January 2010** 

**Equipment:** # **Supplied air respirator (pressure-demand SCBA or airline res pirator with** 

**escape bottle)** # **Chemical resistent clothing** # **Outer gloves, chemical resistent** # **Inner gloves, chemical resistent** # **Chemical resistent safety (steel-toe and shank) boots Optional Equipment includes long cotton underwear, hard hat, disposable gloves and**  **boot covers, cooling unit, 2-way radios.**  **Level C - Conditions allow the use of air-purifying respirators. Criteria include:** 

# **Oxygen concentrations not less than 20%.** # **Concentrations of identified contaminants will be reduced by the respi rator**  **below the contaminants TLV, and the concentration is within the se rvice limit**  **of the canister/cartridge.** # **Concentrations of contaminants to not exceed IDLH levels.** # **Low potential for splash, immersion or potential exposure to highl y toxic**  **materials.** # **FID or PID measurements show concentrations only a few ppms above background.**  **Equipment:** # **Air-purifying, full-face respirator with appropriate canister or ca rtridges** 

# **Chemical resistent clothing** # **Outer gloves. Chemical resistent** # **Chemical resistent safety (steel-toe and shank) boots Optional Equipment includes long cotton underwear, hard hat, disposable gloves and**  **boot covers, escape mask, hard hat, 2-way radios.**  **Level D - No respiratory or skin hazards exist. Criteria include:** 

# **No contaminants present.** # **No potential for splash, immersion or potential exposure to any chemicals. Equipment:**  # **Coveralls or work clothing**

# **Safety shoes/boots** # **Safety glasses** # **Hard hat Optional Equipment includes gloves, face shield.** **DEECO Health and Safety Plan Page 70 January 2010**

5.5 Training for the Use Personal Protective Equipment **DEECO will provide training to each employee who is required to use PPE. Each s uch employee**  **will be trained to know when PPE is necessary, what PPE is necessary, how to properly don, doff,**  **adjust, and wear PPE, the limitations of the PPE, and the proper care, maintenance, useful life and**  **disposal of the PPE. Each affected employee will be required to demonstrate an underst**  **anding of the training and the ability to use PPE properly, before being allowed to perform work requi**  **ring the use of PPE. When DEECO has reason to believe that any affected employee who**  **has already been trained does not have the understanding and skill required, DEECO will retrain each such employee.**  **Circumstances where retraining is required include, but are not li mited to, situations where changes**  **in the workplace render previous training obsolete, changes in th e types of PPE to be used render**  **previous training obsolete, or inadequacies in an affected employee 's knowledge or use of assigned**  **PPE indicate that the employee has not retained the requisite understanding or skill**

**. DEECO will verify that each affected employee has received and**  **understood the required training through a written certification that contains the name of each emp**  **loyee trained, the date(s) of training, and that identifies the subject of the certification.** Holcim (US) Inc. 122 West Carpenter Freeway Suite 485 Irving, Texas 75039 Phone 214-596-9760 800-326-1821 Fax 214-596-0767 www.holcim.com/us

March 30, 2010 Mr. Keith Barnett US EPA Mailroom (D243-02) 109 T.W. Alexander Drive Research Triangle Park, NC 27711

RE: Holcim Submittal to the EPA Section 114 for the Collection of HCL Emission Data

Dear Mr. Barnett: On February 3, 2010, the Environmental Protection Agency (EPA) requested information from Holcim (US), Inc., pursuant to Section 114 of the Clean Air Act (CAA). As part of this request Holcim was required to test the facilities shown in Table 1 for HCL emissions using EPA Method 321 of Appendix A, 40 CFR Part 63. 

## Table 1. EPA HCL 114 Request Facility City, State Holcim (US), Inc. Ada, Oklahoma Holcim (US), Inc. Theodore, Alabama Holcim (US), Inc. Portland, Colorado Holcim (US), Inc. Devils Slide, Utah Holcim (US), Inc. Dundee, Michigan Holcim (US), Inc. Mason City, Iowa

EPA allowed for other kilns to be substituted for kilns listed in Table 1 if those kilns were currently shut down or for some reason could not be tested in the time frame specified. Table 2 provides a list of the Holcim facilities that were tested as part of this 114 request.

## Table 2. Holcim HCL Testing Status Facility City, State Status Holcim (US), Inc. Ada, Oklahoma Completed Holcim (US), Inc. Devils Slide, Utah Completed Holcim (US), Inc. Ste. Genevieve Completed Holcim (US), Inc. Portland, Colorado 29-Mar Holcim (US), Inc. Catskill, New York TBA April Holcim (US), Inc. Midlothian, Texas TBA April Please find enclosed a copy of a site s pecific test protocol and the HCl findings for the Ada, Devils Slide, and Saint G enevieve Plants. The Portland, Colorado facility is being tested the week of March 29 th and upon completion its findings will be submitted to EPA. At the time of the 114, the Theodore plant was down and the Dundee and Mason City plants were shutdown. Therefore, Holcim substituted the Catskill and Midlothian pl ants. Catskill and Midlothian were down most of February and March; however , these plants will be tested during the month of April. While this is beyond t he March 31st date, Holcim will continue to test into April and HCl emission data for Catskill and Midlothian will be submitted to EPA upon completion. Currently Catskill is scheduled for the week of April 9th and Midlothian for the week of April 26. If you have any questions or comments please feel free to contact me at 972- 268-1139.

Sincerely, HOLCIM (US), INC.

Hector Ybanez Corporate Manager, Environmental**DEECO Inc. 3404 Lake Woodard Road**  **Raleigh, NC 27604 (919) 250-0285 (ph); (919) 250-1835 (Fax)**  **www.stacksampling.com**



## Site-Specific Test Plan U.S. EPA Information Collection Request

for Hydrogen Chloride Emissions

from Portland Cement Manufacturing Facilities

**Holcim (US) Inc. - Devils Slide Plant 6055 East Croydon Road**  **Morgan, Utah 84050**

Submitted By: DEECO, INC. 3404 Lake Woodard Road Raleigh, NC 27603 February 20, 2010

Proposed Test Date: February 24-25, 2010TABLE OF CONTENTS

Section Page **1.0 INTRODUCTION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1**  **1.1 Summary of Test Program . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1**  **1.2 Test Program Organization . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1** 
**2.0 SOURCE DESCRIPTION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3**  **2.1 Process Description . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3**  **2.2 Control Equipment Description . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4** 
**3.0 TEST PROGRAM . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5**  **3.1 Objectives . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5**  **3.2 Test Matrix . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5** 
**3.3 PROCESS PERFORMANCE INFORMATION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7**  **3.4 Test Coordination . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7** 
**4.0 SAMPLING LOCATIONS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9**  **4.1 Flue Gas Sampling Location . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9** 
**5.0 SAMPLING AND ANALYTICAL PROCEDURES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11**  **5.1 Test Methods . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11**  **5.2 Sampling Point Determination - EPA Method 1 . . . . . . . . . . . . . . . . . . . . . . . . . 11**  **5.3 Flue Gas Velocity and Volumetric Flow Rate - EPA Method 2 . . . . . . . . . . . . . 11**  **5.4 Outlet Flue Gas Composition - EPA Method 3A . . . . . . . . . . . . . . . . . . . . . . . . 11**  **5.5 Flue Gas Moisture Content - EPA Method 4 . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11**  **5.6 Oxygen, Carbon Dioxide, and Hydrogen Chloride - EPA Methods 3A and 321**

**. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12**  **5.6.1 Test Equipment Description . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12**  **5.6.2 Conditioning and Operational Test Periods . . . . . . . . . . . . . . . . . . . . . . . 14 5.6.3 Test Requirements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .**  **. . . . . 14 5.6.4 Test Procedures for EPA Method 3A . . . . . . . . . . . . . . . . . . . . . . . . . . . 14**  **5.6.4 Calibration Gases . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15**  **5.6.5 Test Procedures . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15**  **5.6.6 Data Acquisition . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16**  **5.7 Test Procedures for EPA Method 321 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16**  **6.0 QA/QC ACTIVITIES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18**  **6.1 QC PROCEDURES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18**  **6.1.1 Manual Sampling Equipment . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18**  **6.1.2 Manual Sampling Equipment Calibration . . . . . . . . . . . . . . . . . . . . . . . . 18**  **6.1.3 Manual Sampling Quality Control Procedures . . . . . . . . . . . . . . . . . . . . 23 7.0 REPORTING AND DATA REDUCTION REQUIREMENTS . . . . . . . . . . . . . .**  **. . . . . . . . 26 Format . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .**  **. . . . . . . . . . . . . . . . . 26 7.2 Data Reduction and Summary . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .**  **. . . . . 27**TABLE OF CONTENTS (continuerd)

Section Page **8.0 PLANT ENTRY AND SAFETY . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 28**  **8.1 Safety Responsibilities . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 28**  **8.2 Safety Program . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 28**  **8.3 Safety Requirements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 28** 
**9.0 PERSONNEL RESPONSIBILITIES AND TEST SCHEDULE . . . . . . . . . . . . . . . . . . . . . 29**  **9.1 Test Site Organization . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 29**  **9.2 Test Preparations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 29**  **9.3 Test Personnel Responsibilities and Detailed Schedule . . . . . . . . . . . . . . . . . . . 29** 

LIST OF TABLES

Table Page **TABLE 3.1 SUMMARY OF SAMPLING AND ANALYTICAL TEST METHODS . . . . . . 6**  **TABLE 3.2 PROGRAM OUTLINE AND TENTATIVE TEST SCHEDULE . . . . . . . . . . . . . 8**  **TABLE 6.1 SUMMARY QA/QC ACTIVITIES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 21**  **TABLE 7.1 EXAMPLE DATA SUMMARY TABLE FOR HYDROGEN CHLOR IDE** 

**EMISSION TEST RESULTS, HOLCIM (US) DEVILS SLIDE FACI LITY, RAW**  **MILL OFF CONDITION; FEBRUARY 25, 2010 . . . . . . . . . . . . . . . . . . . . . . . 27**

LIST OF FIGURES Figure Page **Figure 1.1 Organization for Holcim (US) Inc. Devils Slide Facility HCl ICR T est Program** 

**. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2**  **Figure 4.1 Schematic of the Main Kiln/Raw Mill Stack sampling location . . . . . . . . . . . . . . . . 10**  **Figure 6.1 Example field data sheet for EPA Methods 2 and 4 . . . . . . . . . . . . . . . . . . . . . . . . . 19**  **Figure 6.2 Example field data sheet for EPA Method 3A . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 20** **HCl ICR Site-Specific Test Protocol Page: 1** 

**Holcim (US) Inc. Revision No: 0**  **Devils Slide, Utah Date: February 20,2010**  

### 1.0 INTRODUCTION

1.1 Summary of Test Program **The U.S. Environmental Protection Agency (EPA), Office of Air Qua lity Planning and**  **Standards (OAQPS) has issued an Information Collection Request (ICR ) to Holcim (US), Inc**  **(Holcim). Under the authority of Section 114 of the Clean Air Act (C AA). The EPA is requesting**  **information on hydrogen chloride (HCl) emissions from nonhazardous waste-b urning kilns at**  **Portland cement manufacturing facilities. This request is in r esponse to comments from Portland**  **cement industry members and its trade association to EPA’s pro posal to amend the national emission**  **standards for hazardous air pollutants for Portland cement manufact uring (74 FR 21136 (May 6,**  **2009)). Holcim has retained DEECO Inc. (DEECO) to conduct the required emi**  **ssions testing. Testing for HCl will be conducted in accordance with EPA Method 321 -**  **Measurement of Gaseous Hydrogen Chloride Emissions At Portland Cement Kilns by Fourier T**  **ransform Infrared (FTIR) Spectroscopy.**  **The EPA has recognized that the manual sampling techniques for HCl (EPA Methods 26 and**  **26A) may have positive biases due to chloride salts (such as amm onium chloride) that, when**  **collected in the sampling train, for chloride ions (Cl -**  **) that is indistinguishable from the Cl -**  **ion formed upon collection of HCl. In addition, a negative bias may als**  **o exist due to condensation and/or removal of HCl on the filter and/or in the sampling probe.**  **Consequently, the EPA has decided that the FTIR measurement by EPA Method 321 is the prefer**  **red technique for determining the concentration of HCl emissions from nonhazardous waste-burning kilns**  **at Portland cement manufacturing facilities (Source http://www.epa.gov/ttn/atw/pcem/p**  **ortland.pdf). The Holcim facility located east Morgan, Utah in Morgan County (de**  **signated as the Devils Slide plant with the physical address of 6055 East Croydon Road, Morgan,**  **Utah 84050) has been one of the Portland cement manufacturing facilities selected as part of the I**  **CR HCl emission tests will be conducted at the main kiln/raw mill**  **stack during two conditions; raw mill on (Mill On) and raw mill off (Mill Off).**  **Testing is anticipated to be conducted February 24-25, 2010.**

1.2 Test Program Organization **Figure 1.1 presents the test program organization, major lines of communication, and names**  **and phone numbers of responsible individuals. HCl ICR Site-Specific Test Protocol**  **Page: 2**

**Holcim (US) Inc. Revision No: 0**  **Devils Slide, Utah Date: February 20,2010**  **EPA OAQPS, Sector Policies and Programs Division**  **Peter Tsirigotis Research Triangle Institute**  **Contract EP -D-06-118**

**EPA Sector Policies and Programs Division**  **Keith Barnett (919)541-5605**  **Barnett.Keitht@epa.gov Holcim (US), Inc.**  **Corporate Contacts Ruksana Mirza**  **or Hector Ybanez**  **Corporate Manager, Environmental**  **(214) 524 - 2814 Hector.Ybanez@holcim.com**  **Holcim (US), Inc. Environmental Contact**  **Timothy Schlosser (734)529-4118**  **Timothy.Schlosser@holcim.com**

EPA report data contact **Ron Meyers (919) 541-5407**  **myers.ron@epa.gov or**  **Barrett Parker (919) 541-5635**  **parker.barrett@epa.gov Holcim (US) Inc.**  **Devils Slide Plant Mr. Kevin Ovard**  **(801) 829-2122 Kevin.OVARD@holcim.com**  EPA Test Method contact **Peter Westlin (919) 541-1058**  **westlin.peter@epa.gov**

**or Gary McAllister**  **(919) 541-1062 mcalister.gary@epa.gov**  **DEECO Project Manager Scott Steinsberger**  **(919)250-0285 deeco@deeco.com** 

**DEECO Field Team**

**Figure 1.1 Organization for Holcim (US) Inc. Saint Genevieve Facility HCl ICR Test Program** **HCl ICR Site-Specific Test Protocol Page: 3** 

**Holcim (US) Inc. Revision No: 0**  **Devils Slide, Utah Date: February 20,2010**  

### 2.0 SOURCE DESCRIPTION 2.1 Process Description **The Devils Slide plant operation includes an on-site quarry, raw material storage, crushing**  **and milling, solid fuel (coal and petroleum coke) storage and milling , liquid fuel storage, one**  **preheater/precalciner cement kiln system, product milling, pr oduct storage, and loading and**  **unloading systems. Cement manufacturing involves chemical and physical processing of l**  **arge quantities of raw materials. The raw materials used include sources of calcium, silica**  **, alumina and iron. These are the components necessary for the manufacture of the cement chemica**  **ls dicalcium silicate, tricalcium silicate, tricalcium aluminate, and tetra-calcium aluminoferri**  **te. The raw feed is prepared for use in the kiln system by sizing, grinding and blending the various raw mat**  **erials to produce the necessary mix for quality production. The prepared raw feed is introduced to**  **the kiln system where it is physically and chemically transformed into clinker, the interme**  **diate product of Portland cement. In the kiln system, the raw materials are exposed to tempera**  **tures reaching up to 3,500** E **F through a countercurrent process in the kiln and a co-current process in the pr**  **eheater. The raw materials are heated to 2,650**  E **F, the temperature required to produce quality clinker. Both on-s ite and off-site**  **sources supply raw materials for cement kiln feed at the Ste . Genevieve plant. Quarry resources**  **include limestone and shale deposits that will comprise part of the raw material blend to become**  **clinker, the principal product. Materials received from off-sit e may include limestone, iron ore, clay,**  **bottom ash, fly ash, bauxite, diaspore, gypsum and other materials as necessary. An important**  **source of raw materials is nonhazardous waste materials from ot her industries that have the proper**  **chemical and physical properties to be used as a raw material sourc e. The Ste. Genevieve plant is**  **designed for these types of materials as sources of calcium, s ilica, alumina and iron. Preparation of**  **raw materials, depending on its source and physical properties, involves primary and secondary**  **crushing, and screening, blending and grinding in the raw mills prior t o entrance into the preheater**  **tower of the cement kiln system. Holcim uses coal and petroleum coke as the primary fuels for t**  **he cement manufacturing process at the Devils Slide plant. Holcim uses coal mills t**  **o prepare raw coal/coke for firing in the precalciner and the kiln. Solid fuels are received at the facil**  **ity by truck and rail. Liquid oils and similar non-hazardous materials are used as a secondary fuel in**  **critical situations such as start-up and back-up. The facility’s equipment design also allows Holcim**  **to beneficially use many other sources of energy bearing, non-hazardous waste materials as suppl**  **emental fuel, such as whole or shredded tires, when available. The preheater/precalc**  **iner pyroprocess is a state-of-the-art design that features five-stage cyclone-type preheater tower, low-NOx p**  **recalciner, and a rotary kiln. The preheater/precalciner portion of the system is located in a t**  **all tower adjacent to the kiln. The low NOx precalciner will be located at the base of the tower. T**  **he precalciner allows the burning fuel to be thoroughly mixed with the kiln feed. Excess heated air from the**  **clinker cooler (tertiary air) will provide combustion air for the precalciner. Preheater/precalci**  **ner kilns feature greater thermal efficiency as compared to long dry or long wet kilns. This results**  **in significantly lower emissions and decreased fuel consumption per ton of clinker produced. To increase**  **energy efficiency even further, hot exhaust gases from the preheater tower are utilize**  **d to dry kiln feed in the raw mills and fuel in the coal mill.** **HCl ICR Site-Specific Test Protocol Page: 4** 

**Holcim (US) Inc. Revision No: 0**  **Devils Slide, Utah Date: February 20,2010**  2.2 Control Equipment Description **Airflow from the raw mill, akali bypass, kiln, and coal mill ar e directed through a common**  **duct to fabric filter baghouses HCl ICR Site-Specific Test Protocol**  **Page: 5**

**Holcim (US) Inc. Revision No: 0**  **Devils Slide, Utah Date: February 20,2010**  

### 3.0 TEST PROGRAM

3.1 Objectives **Testing for HCl will be conducted in accordance with EPA Method 321 - Measureme nt of**  **Gaseous Hydrogen Chloride Emissions At Portland Cement Kilns by Four ier Transform Infrared**  **(FTIR) Spectroscopy. The EPA has recognized that the manual sampling techniques for HCl**  **(EPA Methods 26 and 26A) may have positive biases due to chloride salts (such as a**  **mmonium chloride) that, when collected in the sampling train, for chloride ions (Cl**  **- ) that is indistinguishable from the Cl**  **- ion**  **formed upon collection of HCl. In addition, a negative bias may als o exist due to condensation**  **and/or removal of HCl on the filter and/or in the sampling probe. Consequently, the EPA has**  **decided that the FTIR measurement by EPA Method 321 is the prefer red technique for determining**  **the concentration of HCl emissions from nonhazardous waste-burning kilns at Portland cement**  **manufacturing facilities (Source http://www.epa.gov/ttn/atw/pcem/p ortland.pdf).**  **The specific objectives in order of priority are:**

C **Measure the emissions of HCl (EPA Method 321) from the Cement Kil n/Raw Mill Stack**  **during two conditions; raw mill on (Mill On) and both raw mill off (Mill Off), and**

C **Concurrent with the HCl measurements, measure the Cement Kiln/R aw Mill Stack**  **volumetric flow rate (EPA Methods 1 and 2), the Cement Kiln/Raw Mi ll Stack oxygen and**  **carbon dioxide content (EPA Method3A), and the Cement Kiln/Raw Mill S tack moisture**  **content. Relevant process information will be collected by plant per**  **sonnel in conjunction with the testing program. The raw process data will be presented a**  **s collected in the appendices of the final report.**  3.2 Test Matrix **Table 3.1 presents the sampling and analytical matrix. HCl ICR Site-Specific Test Protocol**  **Page: 6**

**Holcim (US) Inc. Revision No: 0**  **Devils Slide, Utah Date: February 20,2010** 

TABLE 3.1 SUMMARY OF SAMPLING AND ANALYTICAL TEST METHODS

Test Parameter Sampling

Method Sample Type Sampling Frequency Analytical Method Measurement Technique

**Volumetric Flow Rate**  **EPA Methods**

**1 and 2 Traverse points;** 

**thermocouple and Pitot tube**  **Concurrent**

**with each Method 321**  **test EPA Method 2** 

**(40 CFR 60, App A) Thermocouple**  **readout and manometer**  **Oxygen and Carbon**  **Dioxide EPA Method** 

**3A Extractive** 

**instrumental sample**  **Concurrent**

**with each Method 321**  **test EPA Method 3A** 

**(40 CFR 60, App A) Paramagnetic**  **for O 2**  **and NDIR for CO**  **2**

**Moisture EPA Method** 

**4 Traverse points;** 

**Condensation Concurrent** 

**with each Method 321**  **test EPA Method 4** 

**(40 CFR 60, App A) Gravimetric** 

**Hydrogen Chloride**  **EPA Method**

**321 Extractive** 

**instrumental sample**  **Three 60-**

**minute test runs per**  **condition EPA Method 321** 

**(40 CFR 63, App A) Fourier**  **Transform Infrared**  **(FTIR) spectrometry** **HCl ICR Site-Specific Test Protocol Page: 7** 

**Holcim (US) Inc. Revision No: 0**  **Devils Slide, Utah Date: February 20,2010**  3.3 PROCESS PERFORMANCE INFORMATION **Plant personnel in conjunction with the testing program will colle ct process information. The**  **raw process data will be presented as collected in the appendices of the f inal report.** 

3.4 Test Coordination **Mr. Kevin Ovard, the Holcim facility contact, will serve as the test coordi nator. He will be**  **responsible for: 1. Scheduling the start of all testing;**  **2. Principal contact with the agency officials concerning the tests; 3. Principal contact with DEECO concerning the tests;**  **4. Recording the process data during the testing; and 5. Providing copies of any field test data to the agency.**  **A tentative test schedule is shown in table 3.2. HCl ICR Site-Specific Test Protocol**  **Page: 8**

**Holcim (US) Inc. Revision No: 0**  **Devils Slide, Utah Date: February 20,2010**  TABLE 3.2 PROGRAM OUTLINE AND TENTATIVE TEST SCHEDULE Sampling Location Parameter(s) Measured Sampling Method Number of Runs

and Duration Length of

Day(s) Day 1 - February 23, 2010 **Arrive on-site and set up test equipment 8 hours** Days 2 & 3 - February 24-25, 2010 **Kiln Stack Flue Gas Flowrate EPA Methods 1, 2, 4 Three 60-minute**  **runs per condition (Mill On and Mill**  **Off) 10 hours**  **O 2**  **/CO 2**  **EPA Method 3A HCl EPA Method 321**  Day 4 - February 26, 2010 **Contingency Day HCl ICR Site-Specific Test Protocol**  **Page: 9**

**Holcim (US) Inc. Revision No: 0**  **Devils Slide, Utah Date: February 20,2010**  

### 4.0 SAMPLING LOCATIONS

4.1 Flue Gas Sampling Location **The kiln/raw mill stack is a vertically-oriented circular st ack with an inside diameter of**  **approximately 134.5". The stack gas sampling ports are located a pproximately 100' (approximately**  **8.9 duct diameters) above the closest disturbance and approximately 25.5' (approximately 2.01 duct**  **diameters) from the stack outlet. The sampling location meets the minimum specifications for**  **selection of a measurement site as outlined in EPA Method 1. A schematic of the Main Kiln/Raw Mill Stack sampling location is shown in Figur**  **e 4.1 HCl ICR Site-Specific Test Protocol**  **Page: 11**

**Holcim (US) Inc. Revision No: 0**  **Devils Slide, Utah Date: February 20,2010** 



### 5.0 SAMPLING AND ANALYTICAL PROCEDURES

5.1 Test Methods **This section contains a brief description of the sampling and analyti cal procedures for each**  **method that will be employed during the test program. All equipm ent, procedures, and quality**  **assurance measures necessary for completion of the test progra m will meet or exceed the**  **specifications of the appropriate methods. Any deviations fr om the methods to ensure quality**  **representativeness of the results are also discussed.** 5.2 Sampling Point Determination - EPA Method 1 **The number and location of the sampling or traverse points will be determined according to**  **the procedures outlined in EPA Method 1. The sample location has alre ady been confirmed to meet**  **EPA Method 1 based on previous source tests. All points will be at least 1.0 inc hes from the stack**  **wall, per Method 1. For the main kiln stack, a total of 12 velocity/i sokinetic traverse points will be**  **used, with six points on each of the two 90o axes** 5.3 Flue Gas Velocity and Volumetric Flow Rate - EPA Method 2 **The flue gas velocity and volumetric flow rate will be determi ned according to the procedures**  **outlined in EPA Method 2. Velocity measurements will be made using type S pitot tubes conforming**  **to the calibration specifications outlined in EPA Method 2, Secti on 10.1. Each Type-S pitot tube,**  **calibrated according to these standards, will have an assigned coef ficient. Differential pressures will**  **be measured with Magnehelic gauges of appropriate range or with fluid manometers. Effluent gas**  **temperatures will be measured with chromel-alumel thermocoupl es equipped with digital readouts.**  5.4 Outlet Flue Gas Composition - EPA Method 3A **Outlet flue gas analysis for oxygen (O 2**  **) and carbon dioxide (CO 2**  **) concentrations, and the calculation of percent excess air and flue gas dry molecular w**  **eight will be performed in accordance with EPA Method 3A. Refer to Section 5.6 for more information** 

5.5 Flue Gas Moisture Content - EPA Method 4 **The flue gas moisture content will be determined in conjunction wit h each sampling run and**  **according to the sampling and analytical procedures outlined in EPA Method 4. The impingers will**  **be connected in series, and contained in an ice bath in order to assure condensation of t he moisture**  **in the flue gas stream. Any moisture that is not condensed in the i mpingers is captured in the silica**  **gel, therefore all moisture can be weighed and entered into moisture content calc ulations.** **HCl ICR Site-Specific Test Protocol Page: 12** 

**Holcim (US) Inc. Revision No: 0**  **Devils Slide, Utah Date: February 20,2010**  5.6 Oxygen, Carbon Dioxide, and Hydrogen Chloride - EPA Methods 3A and 321 **A CEM system will be used to determine oxygen and carbon dioxide concentrations and**  **hydrogen chloride concentrations on the Main Kiln/Raw Mill stack. The procedures used in meeting**  **these requirements are detailed below.** 5.6.1 Test Equipment Description **The instrumentation and all sampling and analytical procedures that will be used by DEECO**  **for the HCl ICR testing will conform with the requirements of E PA Test Methods 3A and 321 using**  **FTIR. For HCl, the extractive system requires that the effluent gas**  **sample be filtered and maintained at a minimum of 356°F (180°C) prior to being delivered to the FTIR s**  **ample cell. The FTIR sample cell will also be maintained at 356°F. The gas sample will**  **be drawn through the extractive system and the FTIR cell using a heated sample pump. The extractive**  **system will be equipped with a glass lined probe also heated to a minimum of 356°F. The probe will**  **be of sufficient length to reach a minimum of three traverse points at 17, 50, and 83 percent of the duct diameter or 0.4, 1.2,**  **and 2.0 meters from the stack or duct wall, which ever is less. All c**  **omponents of the sampling system which contact the sample will be either of glass, stainless steel, or Teflon**  **The extracted gas sample exiting the heated sample pump wi ll be conditioned to remove**  **moisture with an ice water-cooled condenser. A gas distribution manifold wil l be used to deliver a**  **representative sample of flue gas to oxygen and carbon dioxide analyzers. Fourier Transform Infrared (FTIR) spectroscopy for Hydrogen Chl**  **oride - FTIR spectroscopy**  **measures vapor phase organic or inorganic compounds which absorb ener gy in the mid-infrared**  **spectral region, about 400 to 4000 cm -1**  **(25 to 2.5 μm). Continuous measurement is made by matching sample absorbance bands with bands in reference spect**  **ra, and comparing sample band intensities with reference band intensities.**  **The principle limitation to FTIR spectroscopy are the pres ence of interfering compounds that**  **also absorb energy in the mid-infrared spectral region. In a c ement kiln stack gas matrix, water vapor**  **(H 2**  **O) and carbon dioxide (CO 2**  **) are the primary interferents that must be incorporated i nto the**  **identification and quantitation method. By choosing the proper analytical region(s) for the HCl spectra, the eff**  **ect of the interfering compounds can be minimized. The analytical regions will be sele**  **cted based on examination of the actual stack gas matrix. (It should be noted that the analytica**  **l region provided as an example in EPA Method 321 (2679-2840 cm**  **-1 ) does not correspond with the entire analytical region for HCl (2600-**  **3100 cm -1**  **). The example cited in Method 321 appears to have been copied from the formaldehyde**  **analytical region used as an example in Method 318.) The FTIR software performs the computation for a single compound b**  **y subtracting all the other compounds (interferants and target) from the absorbance spec**  **tra and quantifies the single compound based on the remain absorbance. The FTIR software provides**  **a Standard Error Calculation (SEC) value that is an indication of how well the identi**  **fication and quantitation has been performed. A high SEC indicates that other interferants have not b**  **een accounted for in the analysis HCl ICR Site-Specific Test Protocol**  **Page: 13**

**Holcim (US) Inc. Revision No: 0**  **Devils Slide, Utah Date: February 20,2010**  **method, and a low SEC is indicative of greater confidence mesurement . Typically, if the reported**  **SEC is greater than half the reported concentration then the results is suspect**

**. A MIDAC I-Series FTIR will be used to determine HCl concent**  **rations according to EPA Method 321. Infrared absorption spectroscopy is performed by directing an infr**  **ared beam through a sample to a detector. The frequency-dependent infrared absorbanc**  **e of the sample is measured by comparing this detector signal (single beam spectrum) to a signal**  **obtained without a sample in the beam path (background). Most molecules absorb infrared radiation and the a**  **bsorbance occurs in a characteristic and reproducible pattern. The infrared spectrum**  **measures fundamental molecular properties and a compound can be identified from its infrared sp**  **ectrum alone. Within constraints, there is a linear relationship between infrared absorption a**  **nd compound concentration. If this frequency dependent relationship (absorptivity) is known (measured),**  **it can be used to determine compound concentration in a sample mixture.**  **Absorptivity is measured by preparing, in the laboratory, standa rd samples of compounds at**  **known concentrations and measuring the FTIR "reference spectra" of these standard samples. These**  **"reference spectra" are then used in sample analysis: (1) compounds are detected by matching sample**  **absorbance bands with bands in reference spectra, and (2) concentra tions are measured by comparing**  **sample band intensities with reference band intensities. Reference spectra for hydrogen chloride and sulfur hexafluoride will**  **be generated from commercially-available calibration gas cylinders. The EPA**  **reference spectra available from the EPA’s Emission Measurement Center are not representative of** **the concentrations (at 189.5 ppm meters and 497.3 ppm-meters) being measured. HCl reference spe**  **ctra at 2 ppm and 5 ppm (16.3 ppm-meters and 40.8 ppm-meters) will be used. Secondly, higher resol**  **ution spectra, compared to the EPA reference spectra, will be necessary due to the low**  **HCl concentrations that are expected and the high moisture levels (up to 35%) that will be encountered. Thir**  **dly, errors have been reported for certain EPA reference spectra, so the entire EPA reference spectra da**  **ta base should be suspect. CAI Model 200 O**  **2 /CO**  **2 Analyzer**  **- The CAI Model 200 O 2**  **/CO 2**  **analyzer houses two measurement principles in one instrument. The oxygen concentrations are measure**  **d using the parapneumatic technique. Because of its sp3 electron orbital distribution, an oxy**  **gen molecule has an unpaired electron and hence displays a magnetic orientation. Since other el**  **ements that display this magnetic phenomenon are not common gasses at normal temperatures, the parap**  **neumatic measurement technique is virtually specific for oxygen. The sample gas flows t**  **hrough a detection cell located in a very strong magnetic field. The magnetic nature of the oxygen cause**  **s the oxygen to move to one side of the detection cell, inducing a pressure differential prop**  **ortional to the oxygen concentration in the detector cell. The analyzer measures this pressure di**  **fferential, converts the pressure differential to an electrical signal, and sends the results as output.**  **The carbon dioxide concentrations are measured using a single -beam photometric system with**  **a micro flow sensor detector. The micro flow detector is a sea led unit filled with carbon dioxide.The**  **instrument consists of an infrared light source, a chopper, a measur ing cell and a micro flow detector**  **filled with carbon dioxide. The infrared light emitted backward is reflected by a reflecting surface**  **and is added to the infrared light emitted forward. Arranged betwe en the infrared light source and**  **the measuring cell is a chopper blade which rotates to modulate the infrared light beam at regular**  **frequency. The modulated infrared light beam thus formed passes thr ough the measuring cell filled**  **with a sample gas where the light energy is partially ab sorbed or attenuated before it reaches the front** **HCl ICR Site-Specific Test Protocol Page: 14** 

**Holcim (US) Inc. Revision No: 0**  **Devils Slide, Utah Date: February 20,2010**  **chamber of the detector. Both the front and rear chambers of the detector are filled with the gas**  **component to be measured. The infrared light energy is partiall y absorbed in the front chamber and**  **residual light is absorbed in the rear chamber, thereby incre asing the pressure in both chambers.**  **Since the detector is designed to produce a pressure difference b etween the front and rear chambers,**  **a slight gas flow is produced through a path connecting these chambe rs with each other. This slight**  **flow is converted into an AC electrical signal by a micro flow sensor.**

5.6.2 Conditioning and Operational Test Periods **The conditioning and operational test periods will be complete d and sampling commenced**  **once all monitors are found to be acceptable.** 5.6.3 Test Requirements **DEECO's extractive measurement system and all sampling and analytical procedures for**  **testing will conform to the requirements of EPA Methods 2, 3A, and 4 of 40 CFR 60 and EPA**  **Method 321 of 40 CFR 63. The extractive monitors require that the effluent gas sample b**  **e conditioned to eliminate any possible interference (water vapor and particulate matter)**  **before being transported and injected into each analyzer. All components of the sampling system that conta**  **ct the sample are Type 316 stainless steel, glass, or Teflon.**  **A heated probe with an in-stack particulate filter, heated sa mple lines, moisture removal trap,**  **a sample pump, and distribution manifold board are used to deliver a represe ntative sample of flue**  **gas to the analyzers. The sampling probes are constructed of 316 stainless steel and are heated**  **electrically to maintain the sample temperature above the dew point. The sample acquisition and conditioning system also includes two inje**  **ction ports: (1) immediately upstream of the analyzers for analyzer lineari**  **ty checks, and (2) at the outlet of the probe for the sampling system bias and calibration drift checks. Thi**  **s arrangement provides both ease in checking the analyzer performance and a means of evaluating the entire monitoring**  **system.** 5.6.4 Test Procedures for EPA Method 3A **All analyzers will be subjected to an interference check sim ilar to the procedures in Section**  **5.4 of EPA Method 20. During calibration, all analyzers’ response wi ll be noted while introducing**  **each calibration gas. If the sum of the interference responses of the test gases for any of the analyzers**  **is greater than 2 percent of the applicable span value, correct ive measures on the analyzer will be**  **taken, up to and including replacement of the analyzer. Calibration procedures will be performed in accordance with EPA**  **methodology. Analyzers will be calibrated before and after each test and a calibr**  **ation check will be done between each test run.** **HCl ICR Site-Specific Test Protocol Page: 15** 

**Holcim (US) Inc. Revision No: 0**  **Devils Slide, Utah Date: February 20,2010**  **The pretest calibrations will consist of the following steps: • Internal (direct) calibration of each analyzer to adjust cal**  **ibration and check linearity. • External (through the entire sampling system) calibration to**  **check the system bias on zero and span gases.**  **The post test calibration will consist of an external system bias cal ibration check.** 
5.6.4.1 Internal Calibration **- Each analyzer will be calibrated using a certified zer o and span (mid**  **or high range as necessary) gas. Zero and span gases will be directed to each analyzer through the**  **appropriate plumbing, the calibration gas flow rates will b e adjusted to the correct flow rate and the**  **analyzer will be adjusted with the appropriate span pot. After the analyzer is properly adjusted the**  **linearity will be checked using a mid range calibration gas. The maximum allowable limit for**  **linearity is 2% of the analyzer range. All analyzers will be shown to be linear within these limits**  **before proceeding.**
5.6.3.2 External Calibration **- The external calibration bias check will be performed by placing the**  **CEM system in the sampling mode and injecting a zero and span g as into the sample line at the probe**  **exit. This check will show if there was any sampling system related bias, and also served as a check**  **of the integrity of the sample line.**
5.6.4 Calibration Gases **DEECO will use EPA Protocol #1 gases for calibration as requir ed by the various reference**  **methods used in this test program. Calibration gases will be selected from previous experience with**  **similar sources and/or from information obtained from the facilit y engineer prior to sampling. Audit**  **gases, if available from federal or state agencies, will be analyzed.**
5.6.5 Test Procedures **At the completion of the pretest calibration routine, the CEM sy stem will be ready for**  **operation. No further adjustments of sample flow rates, analyz er zero or span adjustments, or other**  **critical CEM operating parameters will be made until te sting and post test calibration are complete.**  **The CEMs will be allowed to at least 21 minutes to complete e ach test run. At the completion for**  **each run, calibration gases nearest to the measured emission le vels will be used to check each**  **instrument. During each sampling run, a sampling traverse will be perfor**  **med to ensure the absence of stratification. Traverse points will be selected that assur**  **e acquisition of representative samples over the stack or duct cross section. A minimum requirement is the esta**  **blishment of a "measurement line" that passes through the centroidal area and in the direction of any e**  **xpected stratification. If this line interferes with the CEM measurements, the line will be displ**  **aced up to 30 cm (12 in.) (or 5 percent of the equivalent diameter of the cross section, whichever is less)**  **from the centroidal area. Per Section 6.5.6.3(a) of 40 CFR 75, three traverse points will be located 16.7,**  **50.0, and 83.3 percent of the measurement line, and measured equally during each run. Alternatively, per Se**  **ction 6.5.6.3(b) of 40 CFR 75, a single sampling point may be used if the concentra**  **tion of each compound at each individual traverse point differs by no more than ±5.0 percent from t**  **he arithmetic average concentration for all traverse points.** **HCl ICR Site-Specific Test Protocol Page: 16** 

**Holcim (US) Inc. Revision No: 0**  **Devils Slide, Utah Date: February 20,2010**  **Concurrent measurements of flow following EPA Methods 1, 2, 3A, and 4 (Sec tions 5.1**  **through 5.5) will be used to determine flue gas emission rates of all target comp ounds.**  5.6.6 Data Acquisition **Data will be recorded on two separate devices. A hard copy wi ll be obtained using a Molytek**  **2702 strip chart recorder. Data will also be recorded to the hard disk of an IBM compatible computer**  **utilizing the serial output of the Molytek recorder in conjunction wi th custom software. Data for each**  **of the analyzers will be sampled each second with a one-minute a verage being written to disk. Data**  **will be further averaged over the test period and corrected f or calibration error and drift using a**  **spreadsheet program.**

5.7 Test Procedures for EPA Method 321 **The FTIR optics and sample cell will be purged with nitrog en overnight. A backgroung**  **spectra will be collected will purging nitrogen thorough the cel l at a flow rate low enough that the cell**  **pressure is not elevated above ambient pressure. Next an ethy lene Calibration Transfer Standard**  **(CTS) will be passed thorough the cell, again at a flow rate low enough that the cell pressure is not**  **elevated above ambient pressure, and spectra will be collecte d of the CTS gas. By setting the cell**  **pressure in the software to reflect the ambient pressure, the path length can be verified and adjusted**  **as needed. As part of the HCl analyte spiking procedure, the calibration g**  **as mixture containing HCl and sulfur hexafluoride (SF**  **6 ) will then be passed directly to the cell, again at a flow**  **rate low enough that the cell pressure is not elevated above ambient pressure.**  **This will establish the undiluted concentration of the HCl/SF**  **6 mixture to be used in the analyte spike recovery calculations.**  **Next the heated sample line will be connected directly to the sample cell, and stack gas will**  **be drawn through the cell prior to the pretest analyte spiking. The first step in the analyte spiking will be to send the CTS**  **to the sample probe and back through the sampling system. Spectra of the CTS gas will be**  **collected and the cell pressure setting in the software will be adjusted as needed to provide the correct CTS reading.**  **After the CTS check is completed, stack gas will again be sa mpled to provide a pre-spike**  **native concentration of HCl. Next the HCl/SF**  **6 gas mixture will be directed to the sample probe at a f**  **low rate approximately 10% of the total sample rate such that the stack**  **gas provides a nominal 10-fold dilution of the analyte spike. Once a satisfactory spike recovery**  **of 70%-130% has been is achieved, the HCl/SF**  **6 gas mixture will be turned off. The HCl/SF**  **6 spike will be purged from the system and**  **additional spectra will be collected from the stack gas to det ermine the post spike concentration of**  **the native HCl. HCl ICR Site-Specific Test Protocol**  **Page: 17**

**Holcim (US) Inc. Revision No: 0**  **Devils Slide, Utah Date: February 20,2010**  **It should be noted that there are errors in the Method 321 equation used to calculate the**  **analyte spike recovery. Consequently the following correct equation will be used;**



### % R C C DF

C DF t n

s 

### = − −      

× × **1 1** 

**1 100** 

**%R = Spike Recovery C**  **t = Concentration of the total HCl (spike plus native), ppm,**  **C n**  **= Average concentration of the native HCl (pre and post spike), ppm, C**  **s = Concentration of the HCl spike, ppm; and**  **DF = Ratio of the undiluted SF 6**  **tracer gas concentration to the diluted SF 6**  **measured during**

**analyte spiking HCl ICR Site-Specific Test Protocol**  **Page: 18**

**Holcim (US) Inc. Revision No: 0**  **Devils Slide, Utah Date: February 20,2010**  

### 6.0 QA/QC ACTIVITIES 6.1 QC PROCEDURES **Example data sheets for EPA Methods 2 and 4 and EPA Method 3A are p rovided in Figures**  **6.1 and 6.2. Specific QA/QC parameters for each method is provided in Tabl**  **e 6.1 and described in detail below.**  6.1.1 Manual Sampling Equipment **Each item of field test equipment will be assigned a unique, per manent identification number.**  **An effective preventative maintenance program is necessary to ensure data quality. Each item of**  **equipment returning from the field will be inspected before it is returned to storage. During the**  **course of these inspections, items are cleaned, repaired, reconditi oned, and recalibrated where**  **necessary. Each item of equipment transported to the field for this test pr**  **ogram will be inspected again before being packed to detect equipment problems which may orig**  **inate during periods of storage. This minimizes lost time on the job site due to equipment failure.**  **Occasional equipment failure in the field is unavoidable despite t he most rigorous inspection**  **and maintenance procedures. For this reason, replacement equipment f or all critical sampling train**  **components will be transported to the job site.** 6.1.2 Manual Sampling Equipment Calibration **New items for which calibration is required will be calibra ted before initial field use.**  **Equipment whose calibration status may change with use or time w ill be inspected in the field before**  **testing begins and again upon return from each field use. When an i tem of equipment is found to be**  **out of calibration, it will be repaired and recalibrated or re tired from service. All equipment will be**  **periodically recalibrated in full, regardless of the outcome of these regula r inspections.**  **Calibrations will be conducted in a manner, and at a frequency, which meets or exceeds U.S.**  **EPA specifications. The calibration procedures outlined in the EP A Methods will be followed.**  **When these methods are inapplicable, methods such as those prescrib ed by the American Society for**  **Testing Materials (ASTM) will be used. Data obtained during calibrations will be recorded on standardize**  **d forms, which will be checked for completeness and accuracy by the quality assurance ma**  **nager. Data reduction and subsequent calculations will be performed using computer facili**  **ties. Calculations will be checked at least twice for accuracy. Copies of calibration forms will be incl**  **uded in the final test report. Emissions sampling equipment requiring calibration includes pitot**  **tubes, pressure gauges, thermometers, dry gas meters and barometers. The following sec**  **tions elaborate on the calibration procedures to be followed for these items of equipment.** **HCl ICR Site-Specific Test Protocol Page: 19** 

**Holcim (US) Inc. Revision No: 0**  **Devils Slide, Utah Date: February 20,2010** 

**Flow rate and Moisture Measurement Data Sheet** Plant and City Date Sampling Location Sample Type Run N o.

Operator Barometric

Pressure (Pb) (In. Hg) Static

Press (in. H2O) Ambient

Temp (deg. F) Stack

ID (In.) Pitot

Cp DGM Box No. DGM delta H@ DGM Cal

Factor (gamma) Probe

ID No. **EPA Method 3/3A Data EPA Method 4 Impinger Weights Oxygen, % Impinger 1 2 3 Sil.Gel**  **Carbon Dioxide, % Final Wt., g Color**  **Nitrogen, % Initial Wt., g % Spent**  **Net Wt., g Total Collected , g**  **EPA Method 2 Data EPA Method 4 Sampling Data**

Run Time (24 hr) Port/Point

ID Pitot

delta P (in. H2O) Stack

Temp (deg. F) Run Time

(24 hr) DGM Reading (cu.ft.) DGM delta H (in. H2O) DGM

Temps (deg. F) Exit

Temp (deg. F) Sample

Train Vac. (In. Hg)

**Initial Leak Rate cfm @ “Hg Final Leak Rate cfm @ “Hg** 

**Pitot Leak Check**

**Figure 6.1 Example field data sheet for EPA Methods 2 and 4 HCl ICR Site-Specific Test Protocol**  **Page: 20**

**Holcim (US) Inc. Revision No: 0**  **Devils Slide, Utah Date: February 20,2010**  **Plant and City Test Location Date Operator**

**Cylinder ID**  **Gas**

**Type Value Internal**  **Response Cal** 

**Error Run No. Run Time** 

**Pre Run Bias**  **Percent**

**Bias Post Run** 

**Bias Percent** 

**Bias Percent** 

**Drift O**  **2 Zero Zero N**  **2 CC5134 O**  **2 Mid 11.9%**  **CC117302 O 2**  **Span 21.9%**

**CO 2**  **Zero Zero N 2**  **CC5134 CO 2**  **Mid 20.4% CC117302 CO**  **2 Span 35.5%** 

**Figure 6.2 Example field data sheet for EPA Method 3A HCl ICR Site-Specific Test Protocol**  **Page: 21**

**Holcim (US) Inc. Revision No: 0**  **Devils Slide, Utah Date: February 20,2010**  TABLE 6.1 SUMMARY QA/QC ACTIVITIES Test Equipment QC Parameter Target **Volumetric Flow Rate Measurement Pitot Tube Pitot Geometry Within Specifications**  **Thermocouple <1.5% absolute Pitot Leak Check stable 15 sec at**  $ **4 in. WC Dry Gas Meters for Particulate Sampling**  **Dry Gas Meters Initial Calibration 0.95** # **γ** # **1.05 individual γ RSD**  # **2% Post Test Calibration Check Post test γ**  # **5% Post Test Leak Checks <2% of sample rate**  **EPA Method 3A Initial Calibration Zero Gas <2% of Span Gas**  **Mid Range Gas <2% of Span Gas Span Gas <2% of Span Gas**  **Bias Checks Zero Gas <5% of Span Gas Mid Range Gas <5% of Span Gas**  **Drift Zero Gas <5% of Span Gas Mid Range Gas <5% of Span Gas**  **Method 321 for Hydrogen Chloride Pre/Post CTS Calibration Precision Pre and post quant**  **ification** # **5% RSD Direct HCl Calibration Precision Duplicate measuremen**  **t** # **5% RSD HCl Analyte Spike System Validation Spike Recovery 70**  **% - 130% HCl ICR Site-Specific Test Protocol**  **Page: 22**

**Holcim (US) Inc. Revision No: 0**  **Devils Slide, Utah Date: February 20,2010**  A: Pitot Tubes. **All Type S pitot tubes used, whether separate or attached to a sampling**  **probe, will be constructed in-house or by a third-party vendor. Eac h new pitot will be**  **calibrated in accordance with Section 10.1 of EPA Method 2. Each Type -S pitot tube,**  **calibrated according to these standards, will have an assigned coe fficient. This**  **coefficient should not change as long as the pitot tube is not damaged. Each pitot tube will be inspected visually upon return f**  **rom the field. If a cursory inspection indicates damage or raises doubt that the pitot rema**  **ins in accordance with the EPA geometry standards, the pitot tube will be refurbis**  **hed as needed and recalibrated.**  B: Differential Pressure Gauge. **All meter consoles used are equipped with 10-inch water column (W.C.) inclined-vertical manometers. Fluid manometers**  **do not require calibration other than leak checks. Manometers will be leak chec**  **ked in the field prior to each test series, and again upon return from the field.**  C: Impinger Thermometer. **Prior to the start of testing, the thermocouple used to monitor the temperature of the gas leaving the last impinger w**  **ill be compared with a mercury-in-glass thermometer which meets ASTM E-1 No. 63F spec**  **ifications. The impinger thermocouple is replaced if it does not agree within**  **2** E **F of the reference thermometer. After each field use, the thermocouple will be c**  **hecked per EPA Alt-011 procedures.**  D: Dry Gas Meter Thermometer. **The thermocouple used to measure the temperature of the metered gas sample will be checked prior to initial f**  **ield use against an ASTM mercury-in-glass thermometer. The dry gas meter thermocouple**  **is acceptable if the values agree within ±2**  E **F. Thermocouples not meeting this requirement will be replaced. After each field use, the thermocouple will be checked**  **per EPA Alt-0011 procedures.**  E: Flue Gas Temperature Sensor. **All thermocouples employed for the measurement of flue gas temperature are calibrated upon receipt. Initi**  **al calibrations will be performed at three points (ice bath, boiling water, and hot oil).**  **An ASTM mercury-in glass thermometer will be used as a reference. The thermocou**  **ple is acceptable if the agreement is within 1.5 percent (absolute) at each of the thre**  **e calibration points. After each field use, the thermocouple will be checked per EPA**  **Alt-011 procedures. Before each field use, the reading from the flue gas thermocouple**  **-potentiometer combination will be compared with an ASTM mercury-in-glass**  **reference thermometer at ambient conditions. If the two agree within ±1.5 pe**  **rcent (absolute), the thermocouple and potentiometer are considered to be in proper working order** 

**.** F: Dry Gas Meter and Orifice. **Two procedures will be used to calibrate the dry gas meter and orifice simultaneously. The full calibration will be**  **a complete laboratory procedure used to obtain the calibration factor of the dry gas me**  **ter. Full calibrations will be performed over a wide range of orifice settings. A s**  **impler procedure, the post test calibration, will be designed to check whether the calibra**  **tion factor has changed. HCl ICR Site-Specific Test Protocol**  **Page: 23**

**Holcim (US) Inc. Revision No: 0**  **Devils Slide, Utah Date: February 20,2010** 

**A dry gas meter that is calibrated annually against a spir ometer or a set of calibrated**  **critical orifices will be used as a transfer standard. Duri ng the annual calibration,**  **triplicate calibration runs will be performed at seven flow rates ranging from 0.25 to**  **1.40 cfm.** G: Dry Gas Meter. **Each metering system receives a full calibration at the time of**  **purchase and a post-test calibration after each field use. I f the calibration factor, γ,**  **deviates by less than five percent from the initial value, the test data are acceptable.**  **If γ deviates by more than 5 percent, the meter is recalibra ted and the meter coefficient**  **(initial or recalibrated) that yields the lowest sample volum e for the test runs is used.**  **EPA Method 5 requires another full calibration anytime the post- test calibration check**  **indicates that γ changed by more than 5 percent. Standard practice is to adjust and**  **recalibrate the dry gas meter anytime γ is found to be outside the range of 0.96 to 1.04.**  **Post-test calibrations will be performed after each field test series per EPA Alt-009**  **procedures.**

H: Orifice. **An orifice calibration factor will be calculated for each flow setting during**  **a full calibration. If the range of values does not vary by more than 0.15 in H**  **2 O over**  **the range of 0.5 to 4.0 in H 2**  **O, the arithmetic average of the values obtained during the calibration is used.** 

I: Barometer. **Each field barometer will be adjusted before each test s eries to agree**  **within ±0.1 inches of a reference mercury-column barometer. The reference**  **barometer will be checked against the station pressure value ( corrected for elevation**  **difference) reported by the National Weather Service.** 6.1.3 Manual Sampling Quality Control Procedures **The following pretest QC checks will be conducted: • All sampling equipment will be thoroughly checked to ensure clea**  **n and operable components.**  **• Equipment will be inspected for possible damage from shipment. • The oil manometer or Magnehelic gauge used to measure pressure**  **across the Type S pitot tube will be leveled and zeroed.**  **• The number and location of the sampling traverse points will be checked before taking**  **measurements. • The temperature measurement system will be visually c**  **hecked for damage and operability by measuring the ambient temperature prior to each run.**  **In addition to the general QC procedures listed above, QC procedures specific to each**  **sampling method will also be incorporated into the sampling scheme. Thes e methods and specific**  **procedures are discussed below. HCl ICR Site-Specific Test Protocol**  **Page: 24**

**Holcim (US) Inc. Revision No: 0**  **Devils Slide, Utah Date: February 20,2010**  **A: Sampling Train QC checks. The following QC procedures will be emphasiz ed:**  Prior to Start of Tests **• Keep all cleaned glassware and sample train components se aled until train**  **assembly. • Assemble the sampling trains in an environment free from contamination.**  **• Visually inspect each sampling train for proper assembly. • Perform pretest calculations to determine the proper sampling nozz**  **le size.**

Prior to Each Test Run **• Visually inspect the sampling nozzle. • Visually inspect the Type S pitot tube.**  **• Leak check each leg of the Type S pitot tube. • Leak check the entire sampling train.**  During Each Test Run **• Readings of temperature and differential pressure will be taken at each**  **traverse point. • All sampling data and calculations will be recorded on p**  **reformatted data sheets.**  **• All sampling data forms will be reviewed for completeness and accurac y.**  **• Any unusual occurrences will be noted during each run on the appropr iate data**  **form. • The project supervisor will review sampling data sheet**  **s daily during testing. • Properly maintain the roll and pitch axis of the Type S p**  **itot tube and the sampling nozzle.**  **• Leak check the train before and after any move from one samp ling port to**  **another during a run (at DEECO’s option) or if a filter change takes place. • Maintain the probe, filter, and impingers at the proper temperatur**  **es. • Maintain ice in the ice bath at all times.**  **• Make proper readings of the dry gas meter, delta P and delt a H, temperature,**  **and pump vacuum during sampling at each traverse point. • Maintain isokinetic sampling within ± 10% of 100%.**  After Each Test Run **• Visually inspect the sampling nozzle. • Visually inspect the Type S pitot tube.**  **• Leak check each leg of the Type S pitot tube. • Leak check the entire sampling train.**  **B: QC for Volumetric air flow rate determinations HCl ICR Site-Specific Test Protocol**  **Page: 25**

**Holcim (US) Inc. Revision No: 0**  **Devils Slide, Utah Date: February 20,2010** 

Flue Gas Velocity. **Data required to determine the flue gas velocity will be col lected**  **using the methodology specified in EPA Method 2. Quality control proce dures are**  **as follows. • Visually inspect the Type S pitot tube before and after sampling.**  **• Leak check both legs of the pitot tube before and after sampling. • Check the number and location of the sampling traverse points bef**  **ore taking measurements.**  Flue Gas Molecular Weight. **Samples to be used for determination of flue gas molecular weight will be collected using the continuous sampling t**  **echnique specified in EPA Method 3A. Quality control will focus on the following procedures:**  **• The sample acquisition system will be leak checked before operation. • A constant sampling rate will be used in withdrawing a sample.**  **• The sampling port will be properly sealed to prevent air in-lea kage.** 

Moisture Content. **The moisture content of the gas stream will be determined usi ng**  **the technique specified in EPA Method 4. The following QC checks wil l be**  **performed: • The sampling train will be leak checked before and after each run.**  **• Ice will be maintained in the ice bath throughout each run. HCl ICR Site-Specific Test Protocol**  **Page: 26**

**Holcim (US) Inc. Revision No: 0**  **Devils Slide, Utah Date: February 20,2010**  

### 7.0 REPORTING AND DATA REDUCTION REQUIREMENTS 7.1 Report Format

**TABLE OF CONTENTS 1.0 Introduction**  **1.1 Summary of Test Program . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . X**  **1.2 Key Personnel . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . X**  **2.0 Source and Sampling Location Descriptions 2.1 Process Description . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .**  **. . . . . . . . X 2.2 Control Equipment Description . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .**  **. . . X 2.3 Flue Gas and Process Sampling Locations . . . . . . . . . . . . . . . . . . . . . . . .**  **X 3.0 Summary and Discussion of Results**  **3.1 Objectives and Test Matrix . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . X**  **3.2 Field Test Changes and Problems . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . X**  **3.3 Summary of Results . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . X**  **4.0 Sampling and Analytical Procedures 4.1 Emission Test Methods . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .**  **. . . X 4.2 Process Test Methods . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .**  **. . . . X 5.0 QA/QC Activities . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .**  **. . . . . . . . . . . . . . X**
**APPENDICES A - Results and Calculations**  **B - Raw Field Data C - CEM Results**  **D - FTIR Results E - Equipment Calibration Data Sheets and Calibration Certificates of Ana**  **lysis F - List of Participants** **HCl ICR Site-Specific Test Protocol Page: 27** 

**Holcim (US) Inc. Revision No: 0**  **Devils Slide, Utah Date: February 20,2010**  7.2 Data Reduction and Summary **An example data summary table is shown as Table 7.1.**

TABLE 7.1 EXAMPLE DATA SUMMARY TABLE FOR HYDROGEN CHLOR IDE

EMISSION TEST RESULTS, HOLCIM (US) DEVILS SLIDE FACI LITY, RAW MILL OFF CONDITION; FEBRUARY 24, 2010 Test Parameter Run X Run X Run X Average **Time xx:xx-xx:xx xx:xx-xx:xx xx:xx-xx:xx ----**  **Stack Gas Temperature (** E **F) xxx xxx xxx xxx Stack Gas Moisture x.x% x.x% x.x% x.x%**  **Volumetric Flowrate actual cfm**  **dry standard cfm xxx,xxx**  **xxx,xxx xxx,xxx** 

**xxx,xxx xxx,xxx** 

**xxx,xxx xxx,xxx** 

**xxx,xxx Oxygen Content x.x% x.x% x.x% x.x%**  **Hydrogen Chloride Emissions Concentration, ppm**  **by volume, wet basis Concentration, ppm**  **by volume, dry basis Concentration, ppm at 7% oxygen**  **x.xx x.xx**  **x.xx x.xx** 

**x.xx x.xx**  **x.xx**

**x.xx x.xx**  **x.xx**

**x.xx x.xx** **HCl ICR Site-Specific Test Protocol Page: 28** 

**Holcim (US) Inc. Revision No: 0**  **Devils Slide, Utah Date: February 20,2010** 



### 8.0 PLANT ENTRY AND SAFETY

8.1 Safety Responsibilities **The DEECO Safety Officer (Dr. Scott Steinsberger) is resp onsible for ensuring compliance**  **with plant entry, health, and safety requirements. The Holcim Devils Slide Plant Contact (Kevin Ovard) has the authority**  **to impose or waive facility restrictions.**  **The DEECO Test Director (Dr. Scott Steinsberger) has authori ty to negotiate with facility**  **person any deviations from the facility restrictions.** 8.2 Safety Program **The DEECO Health and Safety Program is attched as Appendix A.** 8.3 Safety Requirements

**All test personnel will adhere to the following standard safety and precautionary measures**  **as follows:**

C **Confine selves to test area only.**

C **Wear hard hats at all times on-site, except inside sample r ecovery trailers**  **and mobile CEM laboratory.**

C **Wear protective shoes or boots in test area.**

C **Wear protective glasses or goggles at the test sites, and other areas as**  **designated.**

C **Have readily available first aid equipment and fire extinguishers. Before or on the first day on-site, the Test Director will**  **fill out the Holcim Contractor Job Safety Plan and the Pre-Shift Hazard Assessme**  **nt form and provide copies to be posted at each test site.** **HCl ICR Site-Specific Test Protocol Page: 29** 

**Holcim (US) Inc. Revision No: 0**  **Devils Slide, Utah Date: February 20,2010**  

### 9.0 PERSONNEL RESPONSIBILITIES AND TEST SCHEDULE

9.1 Test Site Organization **The key tasks and task leaders are:**

C **Management:** William G. DeWeeS

C **Test Preparation/Site Restoration:** Scott C. Steinsberger

C **Modifications to Facility/Services:** Kevin Ovard

C **Sampling Site Accessibility:** Kevin Ovard

C **Sample Recovery:** John Martin

C **Daily Sampling Schedule:** Scott C. Steinsberger 9.2 Test Preparations **No special sampling and analytical equipment is needed. No modifi cations to the facility are**  **needed. Suitable safe access to the sampling location currently exists. Holcim will provide the**  **necessary electrical power. Sample recovery of the Method 4 tr ains will be conducted in a mobile**  **recovery laboratory already on-site.** 9.3 Test Personnel Responsibilities and Detailed Schedule **DEECO personnel will arrive at the plant about 1.5 hours before the start of the first test run**  **on each of the two days scheduled for sampling. Pre-test activities on these days wi ll include:** 

C **Meet with the plant contact to review the daily test objectives.**

C **Prepare and set-up (including leak checks) the manual method trains at all test locations.** 

C **Calibrate instrumental analyzers and verify that the data ac quisition systems are**  **functioning properly.**

C **Verify communication links between team members/leaders/plant per sonnel.** 

## Appendix A DEECO Health and Safety Plan**DEECO Inc. 3404 Lake Woodard Road**  **Raleigh, NC 27604 (919) 250-0285 (ph); (919) 250-1835 (Fax) www.stacksampling.com** 

**DEECO**
**HEALTH AND SAFETY PLAN**

**January 2010 DEECO**  Health and Safety Plan

**Section Page**  **1.0 Introduction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1**  **1.1 Responsibilities . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1**  **1.2 Employee Conduct . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2**  **1.3 Pre-Work Safety Considerations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4**  **1.4 Employee Safety Education, Training, and Evaluation . . . . . . . . . . . . . . . . . . . . . 4**  **2.0 General Safety Requirements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7**  **2.1 First Aid for Accidents and Injuries . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7**  **2.2 Audit/Inspection Procedures . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8**  **2.3 Bloodborne Pathogens . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9**  **2.4 Aerial Devices (Man Lifts) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9**  **2.5 Confined Space Entry . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11**  **2.6 Documented Safety Meetings . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11**  **2.8 Electrical - GFCI or Grounding Program . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12**  **2.9 Equipment Inspection/Maintenance . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13**  **2.10 Excavation/Trenching/Shoring . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13**  **2.11 Floor/Wall Openings . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14**  **2.12 Hearing Conservation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16**  **2.13 Housekeeping . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18**  **2.14 Manual Lifting . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 19**  **2.15 Mechanical Lifting . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 19**  **2.16 Mechanical and Electrical Safety . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 19**  **2.17 New Employee Orientation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 20**  **2.18 Power and Hand Tools . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 20**  **2.19 Process Safety Management . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 20**  **2.20 Scaffolding . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 21**  **2.21 Stairways and Ladders . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 22**  **2.22 Travel Safety . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 24**  **2.23 Thermal Stress . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 24**  **2.24 Welding and Cutting . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 26**  **2.26 Lockout/Tagout (LOTO) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 26**  **2.27 Fall Protection . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 27**  **2.28 Combustible Gas (LEL), Carbon Monoxide, Hydrogen Sulfide, and/or Ox ygen**  **Monitors . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 38**  **2.29 Emergency Response/Evacuation Program . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 41**  **2.30 Compressed Air Systems . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 42**  **2.31 Concrete Construction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 42**  **2.32 Powder-Actuated Tools . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 42** **Section Page** 

**3.0 Chemical Safety Guidelines . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 43**  **3.1 General Characteristics . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 45**  **3.2 Acids . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 47**  **3.3 Bases . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 47**  **3.4 Compressed Gases . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 48**  **3.5 Cryogenic Materials . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 50**  **3.6 Flammable Liquids and Gases . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 51**  **3.7 Organic Solvents . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 52**  **3.8 Oxidizing Agents . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 53**  **3.9 Asbestos Awareness . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 53**  **3.10 Benzene Awareness . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 54**  **3.11 Hydrogen Sulfide Awareness . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 54**  **3.12 Lead Awareness . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 56**  **4.0 Hazard Communication Requirements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 57**  **4.1 Material Safety Data Sheets . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 59**  **4.2 Chemical Labelling . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 60**  **4.3 Employee Exposure Monitoring . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 61**  **4.4 Employee Medical Surveillance . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 61**  **4.5 Employee Access to Records . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 61**  **5.0 Personal Protective Equipment . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 63**  **5.1 Respiratory Protection . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 63**  **5.2 Gloves . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 66**  **5.3 Protective Eyewear . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 66**  **5.4 Protective Clothing . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 67**  **5.5 OSHA Levels of Protection . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 68**  **5.5 Training for the Use Personal Protective Equipment . . . . . . . . . . . . . . . . . . . . . . 70** **DEECO Health and Safety Plan Page 1 January 2010**



### 1.0 Introduction **DEECO, Inc. (DEECO) is committed to the health and safety of its empl oyees. In order to ensure**  **that all tasks are performed safely, this Health and Safety Plan (HSP) has been prepared. The**  **procedures detailed in this HSP outline individual responsibilities, specific operating procedures,**  **training requirements, and specific information on potential safety and health ha zards.**  **The hazards faced by DEECO field personnel are varied, and speci fic controls of many hazards are**  **the responsibility of the client. This HSP will enable employees to rec ognize potential hazards so**  **that the client may take actions to correct the condition before t he work is performed. This HSP also**  **identifies DEECO activities which may pose significant health and safet y risks.**  1.1 Responsibilities **This section details the responsibilities for employees and ma nagement in the implementation of the**  **HSP.**

President **The President of DEECO has overall responsibility for compliance with all applicable federal and**  **state regulations and the provisions of this HSP. Periodic meeting s with managers and employees**  **should be conducted to discuss:**

# **The importance of health and safety.** # **Changes in regulations regarding health and safety.** # **Recent employee monitoring results.** # **Any recent employee accidents/injuries and possible preventive measures to avoid**  **a recurrence. In addition to the above responsibilities, the President is responsi**  **ble for authorizing any deviations from the HSP.**  Managers **Project managers and field team leaders are responsible fo r the health and safety of all persons**  **assigned to the specific project. Project managers and field team lea ders must ensure that:**  # **Employees are properly trained to perform all tasks in a safe manner.** # **Proper personal protective equipment are available and in good wor king condition.**  # **Persons using personal protective equipment have been instructed on their use.** # **Emergency equipment is available and in good working condition.** # **Employees are informed of any exposure monitoring performed in thei r work area**  **that may be representative of their chemical exposure.** # **All safety considerations have been discussed with the client prior to mobil ization.**  # **All aspects of the projects have been discussed and are underst ood with the team**  **leader and team members.** # **All appropriate safety equipment is available and in good working condition prior to**  **mobilization.** # **All records (employee training, respirator fit-testing, etc .) are present for all team** **DEECO Health and Safety Plan Page 2 January 2010 members.**  # **Copies of MSDSs for all chemicals used by DEECO are available for the c lient.**  # **All tasks are performed in a safe manner.** # **All accidents, injuries, or spills are reported immediately.** # **Any unsafe condition is reported immediately.** # **They cooperate with any monitoring surveys.** DEECO Safety Officer **The DEECO Safety Officer (SO) is responsible for the revi ew and maintenance of the Health &**  **Safety Plan. In addition, the SO is responsible for:** # **Identifying when employee exposure monitoring is necessary.** # **Writing exposure reports and reporting results to the appropria te department manager**  **and employees.** # **Ensuring that appropriate employee training is provided.** # **Investigating reported accidents with department managers.** # **Ensuring that new information on health, safety, employee training, or changes in**  **legal requirements are conveyed to the Director of Field Services.** 1.2 Employee Conduct **Appropriate employee conduct is essential in conveying a profess ional image to DEECO clients.**  **When performing work on client premises:** # **Dress professionally.** # **Contact the team leader if problems with a client arises.** # **Discuss disagreements with other DEECO personnel in private, not in front of the**  **client.** # **Do not discuss DEECO company policies or practices with client s (e.g. management,**  **compensation. etc.)** # **Direct all questions regarding sampling or project activities to the te am leader.**  # **Do not convey DEECO in a negative manner to clients. Any disagree ments with**  **company practices should be discussed directly with your manager.** # **Do not volunteer data to client employees.** # **Release data only to the designated client contact.** # **Do not promise a date for the final report. Have the client c ontact the project**  **manager or coordinator for a final report date.** # **Remain busy while on the client's premises.** # **Remain within designated areas of plant site.** # **Notify team leader when leaving area.** # **Notify client when leaving site for lunch or the end of the day.** # **Be on time for client meetings. If problems arise, call the client im mediately if the**  **scheduled time cannot be kept.** # **Follow all rules and regulations of the client while on the plant site.** # **If approached by the news media, do not offer any information. Refer all questions**  **to the client. DEECO Health and Safety Plan Page 3 January 2010** 

Drugs and Alcohol Use **It is DEECO's desire to provide a drug-free, healthful, and safe workplace. To promote this goal,**  **employees are required to report to work in appropriate mental and physical condition to perform**  **their jobs in a satisfactory manner. While on DEECO premises and while conducting business-related act**  **ivities off DEECO premises, no employee may use, possess, distribute, sell, or be under the infl**  **uence of alcohol or engage in the unlawful manufacture, distribution, dispensation, possession, or use of ill**  **egal drugs. Violations of this policy may lead to disciplinary action, up to and including i**  **mmediate termination of employment, and/or required participation in a substance abuse re**  **habilitation or treatment program. Such violations may also have legal consequences.**  **The legal use of prescribed drugs is permitted on the job only if it does not impair an employee's**  **ability to perform the essential functions of the job effecti vely and in a safe manner that does not**  **endanger other individuals in the workplace. To inform employees about important provisions of this policy, DEEC**  **O has established a drug-free awareness program. The program provides information on the dangers**  **and effects of substance abuse in the workplace, resources available to employees, and cons**  **equences for violations of this policy.**  **Employees with questions or concerns about substance dependency or ab use are encouraged to**  **discuss these matters with their supervisor or the Personnel Di rector to receive assistance or referrals**  **to appropriate resources in the community. Employees with drug or alcohol problems that have not resulted in, a**  **nd are not the immediate subject of, disciplinary action may request approval to take unpai**  **d time off to participate in a rehabilitation or treatment program through DEECO's health insur**  **ance benefit coverage. Leave may be granted if the employee agrees to abstain from use of the**  **problem substance; abides by all DEECO policies, rules, and prohibitions relating to conduct in the wor**  **kplace; and if granting the leave will not cause DEECO any undue hardship.**  **Under the Drug-Free Workplace Act, an employee who performs work f or a government contract**  **or grant must notify DEECO of a criminal conviction for drug- related activity occurring in the**  **workplace. The report must be made within five days of the conviction. Employees with questions on this policy or issues related to drug or**  **alcohol use in the workplace should raise their concerns with their supervisor or the Personnel D**  **irector without fear of reprisal.**

Abusive Language **Abusive or vulgar language, ethnic or sexual slurs and insults will not be tolerated on client or**  **DEECO premises. Use of such language is not only offensive, but may be seen as illegal**  **harassment. Inappropriate language or insults can result in imm ediate, appropriate action upon the**  **employee by DEECO. If problems with employee use of such l anguage occurs, notify your manager.** **DEECO Health and Safety Plan Page 4 January 2010**

1.3 Pre-Work Safety Considerations **The Project Coordinator or Manager should determine through a site visit, or through extensive**  **conversations with the client, if any unusual safety hazards exist at the work site. Additional**  **equipment, if needed, should be determined by the Project Coordinator/Ma nager and the DEECO**  **S.O.** 1.4 Employee Safety Education, Training, and Evaluation **All DEECO personnel shall initially receive the equivalent of t he OSHA 40-hour Training for**  **Hazardous Waste Operators. The 8-hour Refresher Training shall b e completed annually by all**  **personnel. Additional training and education may be required for specific jo**  **b responsibilities. The training requirements for additional education shall be set by the President.**  Employee Safety Evaluation Program **An annual evaluation of each employee’s safety performance will be conducted. Evaluating an employee’s safety performance involves measuring t**  **he level at which employees are achieving both their own personal safety goals and the company’s ex**  **pected safety performance standards. Integrating health and safety into a performance apprai**  **sal system provides management with a unique opportunity to tie the employee’s accountabilities a**  **nd achievements to the company’s objectives and strategic plans.**  **The goals of the Employee Safety Evaluation Program are; 1. Communicating information to employees on how well they are mee**  **ting the health and safety performance expectations of their jobs;**  **2. Identifying areas for coaching to help employees improve their health and safety performance**  **and develop safe work practices; 3. Providing opportunities to further communicate the organization’s**  **health and safety performance expectations;**  **4. Supporting the organizational succession plan; 5. Providing feedback to the organization about its recruitment and s**  **election process as well as its integrated health and safety training/development program;**  **6. Providing feedback about the employee’s perceptions of the compa ny’s health and safety**  **performance and standards. For employees, meeting the health and safety expectations of a job requires**  **them to: 1. Report hazards or hazardous conditions to their supervisor;** **DEECO Health and Safety Plan Page 5 January 2010**

**2. Work in a safe manner at all times by using appropriate pr otective gear and controls on**  **equipment; 3. Follow company policies and procedures;**  **4. Wear personal protective equipment as instructed; 5. Participate in health and safety initiatives (e.g. ergonomic a**  **ssessment, hygiene testing etc.) For supervisors, meeting the health and safety expectations of a job require**  **s the ability to: 1. Coach employees on safe work practices;**  **2. Enforce company policies and procedures; 3. Act as a positive role model for staff with respect to safe work practi**  **ces; 4. Support any staff who are members of the joint health and safety committee;**  **5. Be aware of their legal requirements under the Occupational Health and Safe ty Act;**  **6. Review new jobs/tasks/processes/equipment for safety concerns; 7. Follow-up on reported concerns in a timely fashion;**  **8. Encourage employee input into safety-related concerns and solution- finding processes; and**  **9. Discipline staff when required for failure to follow safety procedures. The Employee Safety Evaluation Program will quantify the health**  **and safety areas being monitored and provide qualitative feedback on employee health and safety performance.**  **The Employee Safety Evaluation Program will evaluate a employ ee’s performance on the following;**  **1. Reporting hazards or hazardous conditions to their supervisor; 2. Working in a safe manner at all times by using appropriate protecti**  **ve gear and controls on equipment;**  **3. Following company policies and procedures; 4. Wearing personal protective equipment as instructed;**  **5. Participating in health and safety initiatives (e.g. ergonomic assessment, hygiene testing etc.)**  **The Employee Safety Evaluation Program will evaluate a supervisor’s performance on the following;** **DEECO Health and Safety Plan Page 6 January 2010**

**1. Effectiveness in managing health and safety issues in their de partment or area of**  **responsibility; and 2. Establishing specific criteria for minimum health and safety standards** 

**. DEECO Health and Safety Plan Page 7 January 2010** 



### 2.0 General Safety Requirements **The procedures and guidelines detailed in the following sections are to be used by DEECO Field**  **personnel while performing work on either DEECO or client premis es. If the client has additional**  **safety procedures, field personnel are to follow the procedures whi ch are more stringent. In all cases,**  **all OSHA, MSHA and/or EPA requirements shall be met.** 2.1 First Aid for Accidents and Injuries **In the absence of an infirmary, clinic, hospital, or physician, that is reas onably accessible in terms**  **of time and distance to the worksite, which is available for the t reatment of injured employees, a**  **person who has a valid certificate in first-aid training from t he U.S. Bureau of Mines, the American**  **Red Cross, or equivalent training that can be verified by documentary evidence, s hall be available**  **at the worksite to render first aid. First aid supplies shall be easily accessible when require**  **d. The contents of the first aid kit shall be placed in a weatherproof container with individual sealed packages**  **for each type of item, and shall be checked by the employer before being sent out on each job a**  **nd at least weekly on each job to ensure that the expended items are replaced.**  **Proper equipment for prompt transportation of the injured pers on to a physician or hospital, or a**  **communication system for contacting necessary ambulance service, shall be provided.**  **In areas where 911 is not available, the telephone numbers of the phy sicians, hospitals, or**  **ambulances shall be conspicuously posted. Where the eyes or body of any person may be exposed to injurious c**  **orrosive materials, suitable facilities for quick drenching or flushing of the eyes and body (e.g. safety showers a**  **nd emergency eyewash systems) shall be provided within the work area for im**  **mediate emergency use. The location of these facilities for quick drenching or flushing of the eyes**  **and body shall be identified and all employees in the affected area will be shown the location of these faci**  **lities. The reporting of any work-related accident, illness, or injury is**  **required by Worker's Compensation regulations. North Carolina law requires that a manager's repor**  **t on an accident or injury be filed within 10 days after the incident.**  **The reporting of incidents will enable employees and management to determine what possible**  **corrective actions can be taken to avoid a recurrence of the incident. Responsibilities**  **Project managers or coordinators must ensure that:** # **Immediate care is obtained for all accidents or injuries.** # **All employee accidents or injuries are recorded on the DEECO A ccident Report form**  **by the employee.** # **Copies of the Accident Report form are sent to the Personnel Director and the**  **DEECO S.O. DEECO Health and Safety Plan Page 8 January 2010** 

# **Accident reports are reviewed with the employee and possible p reventive measures**  **are noted and implemented if required.** # **Any equipment involved in an incident is removed from service until re paired or**  **replaced. The Personnel Director must ensure that:**  # **Necessary North Carolina forms are completed, distributed, and ma intained for any**  **occupational injury or accident.** # **The OSHA Form 300 is updated and posted on the bulletin board in the Br eak Room.**  **Employees must ensure that:** # **All accidents or injuries are reported immediately to the D epartment Manager,**  **Project Manager, or Project Coordinator.** # **All details of the accident or injury are recorded on the DEECO Accident Report**  **form.** 2.2 Audit/Inspection Procedures **Safety audits and inspections of all work areas will be conducted periodically by the Safety Officer**  **or a representative thereof. Procedures for conducting an inspection of a job site will be as follows.**  **The following items, while not inclusive, are indicators of some of t he areas of concern for good job**  **site safety covered in a routine inspection or audit. Item**  **Acceptable Not Acceptable**  **NA Employee Safety Training ( ) ( ) ( )**  **Safety Manual On site ( ) ( ) ( ) Assigned Responsibilities ( ) ( ) ( )**  **Confined Space Entry ( ) ( ) ( ) Fire Protection ( ) ( ) ( )**  **Electrical - GFCI or Grounding Program ( ) ( ) ( ) Equipment Inspection/Maintenance ( ) ( ) ( )**  **Excavation/Trenching/Shoring ( ) ( ) ( ) Floor/Wall openings ( ) ( ) ( )**  **Hearing Conservation ( ) ( ) ( ) Housekeeping ( ) ( ) ( )**  **Mechanical Lifting ( ) ( ) ( ) Mechanical and Electrical Safety ( ) ( ) ( )**  **Power Tools ( ) ( ) ( )**  **Scaffolding ( ) ( ) ( )**  **Stairways and Ladders ( ) ( ) ( ) Travel Safety Followed ( ) ( ) ( )**  **Thermal Stress ( ) ( ) ( ) Chemical Safety Guidelines Met ( ) ( ) ( )**  **Hazard Communication Requirements Met ( ) ( ) ( ) Material Safety Data Sheets On site ( ) ( ) ( )**  **Chemical Labelling Clear and correct ( ) ( ) ( ) Personal Protective Equipment ( ) ( ) ( )** **DEECO Health and Safety Plan Page 9 January 2010**

**Respiratory Protection ( ) ( ) ( ) Gloves**  **( ) ( ) ( ) Protective Eyewear ( ) ( ) ( )**  **Protective Clothing ( ) ( ) ( ) Fall Protection ( ) ( ) ( )**  2.3 Bloodborne Pathogens **In the normal course of work, it is not reasonably anticipated that DEECO employees will encounter**  **occupational exposure of the skin, eye, mucous membrane, or parentera l contact with blood or other**  **potentially infectious materials. Consequently, DEECO is not requi red to have a written Exposure**  **Control Plan. However, in the case of an accident, all contact with blood or blood pr**  **oducts should be avoided to prevent the risk of exposure to bloodborne pathogens, . Cuts, scrap**  **es, and abrasions should be reported to the safety officer or appointed representative and pr**  **oper health care should be provided by trained personnel. Rubber gloves should be worn at all times w**  **hen treating injuries causing risk to bloodborne pathogens.**  **Rubber gloves, protective resuscitation masks, and other first aid items are contained in the field first**  **aid kit which is to be present on each project.** 2.4 Aerial Devices (Man Lifts) **On occasions, DEECO employees may be required to use aerial devices (man lifts) to access**  **sampling locations. The following are examples of aerial devices; 1. An aerial device is any vehicle-mounted device, telescoping or ar**  **ticulating, or both, which is used to position personnel;**  **2. An aerial ladder is an aerial device consisting of a single - or multiple-section extensible**  **ladder; 3. An articulating boom platform is an aerial device with two or**  **more hinged boom sections.; 4. An extensible boom platform is an aerial device (except la**  **dders) with a telescopic or extensible boom. Telescopic derricks with personnel platform a**  **ttachments shall be considered to be extensible boom platforms when used with a personnel plat**  **form; 5. An insulated aerial device is an aerial device designed for wor**  **k on energized lines and apparatus;**  **5. A mobile unit is a combination of an aerial device, its vehicle, and related equipm ent;**  **6. A platform is any personnel-carrying device (basket or bucket) which is a component of an**  **aerial device; 7. A vehicle is any carrier that is not manually propelled; and** **DEECO Health and Safety Plan Page 10 January 2010**

**8. A vertical tower is an aerial device designed to elevate a p latform in a substantially vertical**  **axis.** Specifc Requirements for Aerial Lifts **Only trained persons shall operate an aerial lift. For ladder trucks and tower trucks, before the truck is moved for highwa**  **y travel, aerial ladders will be secured in the lower traveling position by the locking device ab**  **ove the truck cab, and the manually operated device at the base of the ladder, or by other e**  **qually effective means (e.g., cradles which prevent rotation of the ladder in combination with positive acting linear ac**  **tuators). For extensible and articulating boom platforms, the lift controls**  **shall be tested each day prior to use to determine that such controls are in safe working condition.**  **Belting off to an adjacent pole, structure, or equipment while worki ng from an aerial lift shall not**  **be permitted. Employees shall always stand firmly on the floor of the basket,**  **and shall not sit or climb on the edge of the basket or use planks, ladders, or other devices for a work position.**  **A body belt shall be worn and a lanyard attached to the boom or bas ket when working from an aerial**  **lift. Boom and basket load limits specified by the manufacturer shall not be exce**  **eded. The brakes shall be set and outriggers, when used, shall be positi**  **oned on pads or a solid surface. Wheel chocks shall be installed before using an aerial lift on an incline.**  **An aerial lift truck may not be moved when the boom is elevated in a working position with men in**  **the basket, except for equipment which is specifically desig ned for this type of operation in**  **accordance with the provisions of OSHA 1910.67, paragraphs (b)(1) and (b)(2). Articulating boom and extensible boom platforms, primarily desi**  **gned as personnel carriers, shall have both platform (upper) and lower controls. Upper controls shall**  **be in or beside the platform within easy reach of the operator. Lower controls shall provide for**  **overriding the upper controls. Controls shall be plainly marked as to their function. Lower level**  **controls shall not be operated unless permission has been obtained from the employee in the lift, except i**  **n case of emergency. Climbers shall not be worn while performing work from an aerial lift.**  **The insulated portion of an aerial lift shall not be altered i n any manner that might reduce its**  **insulating value. Before moving an aerial lift for travel, the boom(s) shall be i**  **nspected to see that it is properly cradled and outriggers are in stowed position, except as provided in OSHA 1910.67,**  **paragraph (c)(2)(viii). DEECO Health and Safety Plan Page 11 January 2010** 

2.5 Confined Space Entry **A Confined Space in an enclosure having limited access and egress. Examples of confined spaces**  **include, but are not limited to:** # **Storage tanks, tank cars, process vessels, bins, silos, boiler s, and other tank-like**  **compartments usually with only a manhole for entry.** # **Open-topped spaces of more than 4 feet in depth, such as pits, vault s and vessels, not**  **subject to good natural ventilation.** # **Septic tanks, sewers, underground utility tunnels, pipelines, and similar struct ures.**  **Confined spaces may contain atmospheres that are hazardous to lif e and health because of the**  **presence of flammable, explosive, or toxic contaminants or becaus e of either a deficiency or excess**  **of oxygen. It is DEECO policy not to permit employees to ente r a confined space. In the event that**  **confined space entry is necessary as part of a project, the client is to provide DEECO personnel with**  **training, life-support equipment, and emergency/rescue personnel duri ng any confined space work.**  2.6 Documented Safety Meetings **Safety Meetings will be held on the first day of a project, on-site. A review of safety conditions will**  **be made by the project manager/field team leader at the end of each day's work. Any unusual or**  **notable health or safety concerns will be noted in the field log, and discussed with all field team**  **members. All field safety meetings will be documented in the field log book, and a copy of the**  **appropriate pages will be included in the final written report to the cli ent.**  **The President shall ensure that meetings are held periodically to address safety violations,**  **procedures, and/or updates. The dates, attendees, and topics of these meetings will be documented**  **and placed in the Safety Meetings file.**

2.7 Fire Protection **Every employee should be aware of the combustible characterist ics of the chemicals and materials**  **they use or may come in contact with. This information can be found on the chemical's Material**  **Safety Data Sheet (MSDS), or labels on the material container. When performing work on a client's site, the Project Manager or Coordinator must:**  # **Be able to clearly identify all regular and emergency ex its in the building or work**  **area.** # **Receive a site evacuation route from the client.** # **Receive emergency notification procedures from the client (e .g. number to call in**  **case of fire, explosion, etc.).** # **Ensure all team members are aware of the above information. Care should be taken when storing or using chemicals or hazardous materials in DE**  **ECO vehicles or mobile laboratories. All vehicles and mobile laboratories are equipped w**  **ith fire extinguisher. If a fire should occur:**  # **Aim fire extinguisher at the base of the fire.** # **Never allow the fire to come between you and an exit.** # **Never use water on electrical or burning liquid fires. If the fire is too large to be contained with one fire extinguisher:** **DEECO Health and Safety Plan Page 12 January 2010**

# **Immediately notify the site emergency contact. Report locat ion of fire, material**  **burning, and if any injuries are involved.** # **Evacuate the area.** Fire Extinguisher Classes
Class A **- for use on ordinary combustible materials such as paper, wood, etc.** Class B **- for use on flammable and combustible liquids, greases, paints, etc.** Class C **- for use on electrical fires.** Class D **- for use on combustible metals. All fire extinguishers located in the DEECO vehicles and mobil**  **e laboratories are rated for Class A, B, and C fires.**  2.8 Electrical - GFCI or Grounding Program **It is the policy of DEECO to establish and implement an assur ed equipment grounding conductor**  **program on work sites covering all cord sets, receptacles whic h are not a part of the permanent**  **wiring of the building or structure, and equipment connected by cord and p lug which are available**  **for use or used by employees. This policy shall apply to all w ork sites not equipped with ground**  **fault circuit interrupters in accordance with OSHA standard 1926.400 (h). The project manager/field team leader shall implement the**  **assured equipment grounding conductor program where existing and predictable hazards are identifyedi**  **the surrounding area or working conditions which are unsanitary, hazardous or dangerous to employees, and**  **who is authorized to take prompt corrective measures to eliminate them.**  **The project manager/field team leader shall be responsible and account able for the following:**  **Each cord set, attachment cap, plug and receptacle of cord set a nd any equipment connected by cord**  **and plug, except cord sets and receptacles which are fixed and not exposed to damage, shall be**  **visually inspected before each day's use for external defects, such as def ormed or missing pins, or**  **insulation damage, and for indication of possible internal damage . Equipment found damaged or**  **defective may not be used until repaired. The project manager/field team leader is responsible for t**  **ests on all cord sets, receptacles which are not a part of the permanent wiring of the building or structure, a**  **nd cord and plug connected equipment repaired to be grounded. Tests shall be documented on the**  **log for assured equipment grounding conductor program and shall be on the job site for inspection**  **by OSHA officials and any affected employee. Equipment that does not meet prescribed tes**  **t shall not be put into service. The following tests shall be performed:**  **1. All equipment grounding conductors shall be tested for continuity and shall be ele ctrically**  **continuous. DEECO Health and Safety Plan Page 13 January 2010** 

**2. Each receptacle and attachment cap or plug shall be tested for correct attachment of the**  **equipment grounding conductor. The equipment grounding shall be connected to it s**  **terminal.. In accordance with OSHA Construction Safety and health Standards 1926.21 Safety**  **Training and Education, project manager/field team leader shall attend such**  **training sessions as the company may deem necessary.**  **A copy of this policy shall be at the job site for inspec tion and copy by OSHA officials and any**  **affected employee. Management retains the authority to designa te that certain jobs comply with**  **regulation 1926.400 (h) by use of ground fault circuit interrupters in li eu of the program established**  **above. A copy of the completed forms will be kept on each appli cable job site for inspection**  **purposes. Electric power operated tools and power cords shall be UL appr**  **oved, double insulated or have the third wire ground whole and in place. All 120-volt single phase, 15- and 20**  **-ampere receptacle outlets on construction sites, which are not a part of the permanent**  **wiring of the building or structure and which are in use by employees, shall have approved ground-fault cir**  **cuit interrupters (GFCI) for personnel protection.**  **All equipment and power cords are to be inspected prior to the fi eld project. Any equipment or**  **power cord which is not in proper working order shall be tagged as "D AMAGED-DO NOT USE"**  **and returned to the DEECO laboratory for repair or replacement.** 2.9 Equipment Inspection/Maintenance **Mechanical and electrical equipment will be periodically insp ected according to the manufacturers**  **instructions to ensure they are in proper working order, all cords and parts are not chipped, frayed**  **or broken, and recommended maintenance procedures are conducted on schedule. E quipment that**  **does not meet safety standards will be repaired or replaced before use.** 2.10 Excavation/Trenching/Shoring **DEECO personnel shall not perform excavation or trenching work, nor sha ll DEECO personnel be**  **expected to enter an excavation or trench. Should such entry be requir ed on a project, the client must**  **ensure: - Underground lines, equipment and electrical cables shall be located, identif**  **ied and de-energized prior to beginning work.**  **- Walls and faces of trenches and excavations, four or more feet de ep, are shored,**  **sloped or shielded as dictated by the type of soil encountered. - Daily inspections are conducted by a competent person for evidenc**  **e of a situation that could result in possible cave-ins, indications of failure of pr**  **otective systems or other hazardous conditions.**  **- Employees are not be permitted underneath loads handled by lifting or digging**  **equipment. Employees shall be required to stand away from any vehi cle being**  **loaded or unloaded. DEECO Health and Safety Plan Page 14 January 2010** 

**- Employees are be protected from excavated or other material s and equipment that**  **could pose a hazard by falling or rolling in excavations. - Physical barriers are be placed around or over trenches and ex**  **cavations. Barriers**

**shall be removed only when necessary to provide access to personnel or equipment.**  **Flashing light barricades shall be provided at night. - A stairway, ladder, ramp or other safe means of egress**  **is located in trench excavations that are four feet or more in depth so as to require no**  **more than 25 feet of lateral travel for employees.**  **- Backfilling and removal of support systems are performed only a fter employees have**  **cleared the area. All excavations shall be backfilled and graded promptl y.**  **- Trenches greater than four feet deep shall require an approved conf ined space entry**  **permit. The client requiring DEECO personnel to enter a trench or exc**  **avation shall provide training to DEECO personnel in accordance to client and OSHA regulations and policies.**  2.11 Floor/Wall Openings **With regards to guarding floor and wall openings and holes, workers wi ll comply with 29 CFR**  **1910.23 and 1926, Subpart M. General requirements are as follows:**  **1. Ladderway floor openings shall be guarded by a standard railing and toe-boards or cover.**  **In general, the railing shall be provided on all exposed sides, exc ept at entrances to stairways.**  **2. Hatchways and chute floor openings shall be guarded by one of the following: a. Hinged covers and a standard railing with only exposed side.**  **b. A removable standard railing with toe-board on not more than two sides and fixed**  **standard railings with toe boards on all other exposed sides. 3. Temporary floor openings, into which persons can accidentally wal**  **k, shall be guarded by either a standard railing with toe-board on all exposed sides, or a**  **floor hole cover that is secured against accidental displacement.**  **4. Wall openings, from which there is a drop of more than four feet , and the bottom of the**  **opening is less than three feet above the working surface, shall be guarded as fol lows:**  **a. A standard rail, if that will effectively reduce the danger of falling. If the bottom of**  **a wall opening is less than four inches above the working surface, a toe-board or an**  **enclosing screen shall also be provided. 5. Every open-sided floor or platform four feet or more above adjac**  **ent floor or ground level shall be guarded by a standard railing or equivalent. A toe-board s**  **hall be provided wherever, beneath the open sides, persons can pass or there is moving machine**  **ry or there is equipment with which falling material could create a hazard.** **DEECO Health and Safety Plan Page 15 January 2010**

**Standard Specifications 1. A standard railing shall consist of top rail, intermediate rail, toe-boa**  **rd and posts, and shall have a vertical height of approximately 42 inches.**  **a. The intermediate rail shall be halfway between the top r ail and the floor, platform**  **runway or ramp. b. Posts shall be spaced not more than eight feet on corners.**  **c. A completed railing structure shall be capable of withsta nding a load of at least 200**  **pounds applied in any direction at any point on the top rail, wit h a minimum of**  **deflection. 2. A standard handrail shall be of a construction similar to a st**  **andard rail except that it is mounted on a wall or partition and does not include an intermediate rail.**  **a. The height to handrails shall not be more than 34 inches or less tha n 30 inches from**  **top surface to tread or ramp. b. Handrails and railings shall be provided with a clearance of a**  **pproximately three inches between the rail and any other object.**  **3. Floor opening covers shall be of any material that meets the following strength requirements:**  **a. The cover, when located in roadways or vehicular aisles, shall be designed to c arry**  **a truck rear axle load of at least two times the maximum intended load. b. The floor opening cover shall be capable of supporting the max**  **imum intended load and so installed as to prevent accidental displacement.**  **4. Wall opening protection shall meet the following requirements: a. Barriers shall be of such construction and mounting that, when in pla**  **ce, they are capable of withstanding a load of at least 200 pounds applied in any di**  **rection (except upward) with a minimum deflection.**  **5. During the performance of work on low pitched roofs, employees shall be protected at all**  **open sides and edges by the use of a motion-stopping safety system. Barricades**  **1. Signs, signals and barricades shall be posted to detour passage of persons and vehicles at**  **locations where potential hazards exist. a. Barricades must be 42 inches high.**  **b. Barricades should be kept four feet back from the edge of ex cavations, holes, and**  **platforms and six feet back from the edge of low-pitched roofs. c. Barricades with flashing lights shall be provided at night.** **DEECO Health and Safety Plan Page 16 January 2010**

**2. All employees engaged in built-up roofing work will undergo traini ng so that they are able**  **to recognize and deal with the hazards of falling associated the w orking near a roof**  **perimeter.** 2.12 Hearing Conservation **DEECO personnel may be exposed to excessive noise levels while on a client's premises. The**  **project manager/field team leader will ensure all high noise areas have been identified, and that each**  **member of the field team is aware of the location of these ar eas. Hearing protection is to be provided**  **by DEECO to field personnel at no cost. Employees will wear hearing protection as instructed and**  **in all areas required.** Hearing Conservation Training Program **DEECO will train each employee who is exposed to noise at or a bove an 8-hour time weighted**  **average of 85 decibels. DEECO will institute a training progr am and ensure employee participation**  **in the program. The training program will be repeated annually for each empl**  **oyee included in the hearing conservation program. Information provided in the training program will**  **be updated to be consistent with changes in protective equipment and work processes.**  **DEECO will ensure that each employee is informed of the effec ts of noise on hearing, the purpose**  **of hearing protectors, the advantages, disadvantages, and attenuation of various types, and**  **instructions on selection, fitting, use, and care, and the purpose of audiom etric testing and an**  **explanation of the audiometric test procedures. DEECO will provide annual audiometric exams for all personnel. T**  **he President is responsible for ensuring compliance with applicable regulations (29 CFR 1910.95, "O**  **ccupational Noise Exposure", and 1926.101, "Hearing Protection").**  Audiometric Testing Program **DEECO will establish and maintain an audiometric testing progr am by making audiometric testing**  **available to all employees whose exposures equal or exceed an 8- hour time-weighted average of 85**  **decibels. The program shall be provided at no cost to employees. Audiometric tests will be be performed by a licensed or ce**  **rtified audiologist, otolaryngologist, or other physician, or by a technician who is certified by the Council**  **of Accreditation in Occupational Hearing Conservation, or who has satisfactorily demonstrated compet**  **ence in administering audiometric examinations, obtaining valid audiograms, and properly u**  **sing, maintaining and checking calibration and proper functioning of the audiometers be**  **ing used. A technician who operates microprocessor audiometers does not need to be certifi**  **ed. A technician who performs audiometric tests must be responsible to an audiologist, otolaryngologist or p**  **hysician. All audiograms obtained pursuant to this section shall meet the r**  **equirements of OSHA 1910, Appendix C: "Audiometric Measuring Instruments."** **DEECO Health and Safety Plan Page 17 January 2010**

Baseline Audiogram **Within 6 months of an employee's first exposure at or above the ac tion level, DEECO will establish**  **a valid baseline audiogram against which subsequent audiograms can be compar ed.**  **Where baseline audiograms are obtained more than 6 months after t he employee's first exposure at**  **or above the action level, employees shall wear hearing prote ctors for any period exceeding six**  **months after first exposure until the baseline audiogram is obtained. Testing to establish a baseline audiogram shall be preceded**  **by at least 14 hours without exposure to workplace noise. Hearing protectors may be used as a subst**  **itute for the requirement that baseline audiograms be preceded by 14 hours without exposure to workplace noi**  **se. DEECO will notify employees of the need to avoid high levels of non-occupational noise exp**  **osure during the 14-hour period immediately preceding the audiometric examination.**  Annual Audiogram **At least annually after obtaining the baseline audiogram, DEEC O will obtain a new audiogram for**  **each employee exposed at or above an 8-hour time-weighted average of 85 decibels.** Evaluation of Audiogram **Each employee's annual audiogram will be compared to that empl oyee's baseline audiogram to**  **determine if the audiogram is valid and if a standard threshold shift (as defined in OSHA**  **1910.95(g)(10)) has occurred. This comparison may be done by a technician. If the annual audiogram shows that an employee has suffered a standa**  **rd threshold shift, DEECO will obtain a retest within 30 days and consider the results of the retest as the annual audi**  **ogram. An audiologist, an otolaryngologist, or a physician will review prob**  **lem audiograms and will determine whether there is a need for further evaluation. DEECO**  **will provide to the person performing this evaluation, a copy of the requirements for hearing**  **conservation as set forth in OSHA 1910.95 paragraphs (c) through (n), the baseline audiogram and most rece**  **nt audiogram of the employee to be evaluated, measurements of background sound pressure le**  **vels in the audiometric test room as required in OSHA 1910Appendix D: Audiometric Test Rooms, and rec**  **ords of audiometer calibrations required by OSHA 1910 paragraph (h)(5).**  Follow-up Procedures **If a comparison of the annual audiogram to the baseline audiogram i ndicates a standard threshold**  **shift, the employee will be informed of this fact in writing, within 21 days of the de termination.**  **Unless a physician determines that the standard threshold shift is not work related or aggravated by**  **occupational noise exposure, DEECO will ensure that the employees not us ing hearing protectors**  **will be fitted with hearing protectors, trained in their use a nd care, and required to use them.**  **Employees already using hearing protectors shall be refitted and retrained in the use of hearing**  **protectors and provided with hearing protectors offering greater attenuati on if necessary.** **DEECO Health and Safety Plan Page 18 January 2010**

**The employee will be referred for a clinical audiological eva luation or an otological examination,**  **as appropriate, if additional testing is necessary or if DEEC O suspects that a medical pathology of**  **the ear is caused or aggravated by the wearing of hearing protectors. The employee will be informed of the need for an otological exami**  **nation if a medical pathology of the ear that is unrelated to the use of hearing protectors is suspected.**  **If subsequent audiometric testing of an employee whose exposu re to noise is less than an 8-hour**  **TWA of 90 decibels indicates that a standard threshold shift is not p ersistent, DEECO will inform**  **the employee of the new audiometric interpretation and mMay disc ontinue the required use of**  **hearing protectors for that employee.**

Revised Baseline **An annual audiogram may be substituted for the baseline audiogram when, in the judg ment of the**  **audiologist, otolaryngologist or physician who is evaluating the audiog ram, that the standard**  **threshold shift revealed by the audiogram is persistent or the hea ring threshold shown in the annual**  **audiogram indicates significant improvement over the baseline audiogram.** 2.13 Housekeeping **Employees shall maintain a high standard of housekeeping on the job a t all times as an integral part**  **of the work The purpose of this requirement is to ensure the safet y of all personnel entering the lob**  **location and to maintain a condition of housekeeping that is consistent wi th the desired appearance**  **of a DEECO job location. Project managers/field team leaders shall clean up work ar**  **eas daily, store all equipment and construction materials in an orderly manner in storage areas. Ba**  **rricades shall be used for temporary storage of equipment and construction materials. All scrap construction mat**  **erials and waste shall be picked up and disposed of at least daily. All location procedur**  **es for waste disposal shall be followed. Form wood and other lumber shall be neatly stored when not**  **in use. All nails shall be removed or bent over to prevent puncture wounds.**  **All stairways, walkways, ladder cages and scaffolds shall be kept clear of all cords, cables, hosed,**  **materials and anything else that might hinder personnel access. Cords, cables and hosed at stairways,**  **walkways and scaffolds will be supported at least seven fee t overhead or laid flat outside of**  **walkways. All spills of oil, solvents, chemicals and any regulated liquids sh**  **all be reported to the site representative immediately and shall be properly cleaned up**  **and disposed of. Dumping of these materials in floor drains, sanitary sewers, storm sewers. drai**  **nage ditches, or other open ground is forbidden.**  **Employees shall be responsible for keeping all location roads f ree from all debris resulting from their**  **performance of the work. Storage of combustible and flammable m aterials shall not be located under**  **overhead pipelines and utilities. Loose materials on roofs or other overhead structures shall be**  **removed or secured to prevent being blown or bumped off. Accumulation of materials that may** **DEECO Health and Safety Plan Page 19 January 2010**

**create a fire hazard shall not be permitted. Storage of mat erials shall be at least eight feet from the**  **center of railroad tracks. Project managers/field team leaders shall perform a housekee**  **ping review of the work site at the end of each day. All concerns noted will be corrected prior to the field team leaving**  **the site.** 2.14 Manual Lifting **When lifting heavy objects, an improper lifting technique may re sult in a serious injury. When**  **lifting objects, ensure that you:** # **Know your limitation. Enlist help before lifting objects that are beyond your**  **strength.** # **Have cleared a path to carry the object, before lifting the object.** # **Lift with your legs, keeping your back straight.** # **Have a firm grip and a sure footing before lifting the object.** # **Lift objects gradually. Avoid jerking motions and awkward positions.** # **Avoid twisting your body when carrying the object. Turn your entire b ody with the**  **object.** 2.15 Mechanical Lifting **Mechanical lifting aids, such as hoists, trucks, dollies, and jacks ar e to be used to assist Field**  **personnel in handling heavy objects. Field personnel must ensure that:**

# **The rated capacity of the mechanical device is not exceeded.** # **When lifting objects to a higher work location, the area below the lifted object is kept**  **clear by restricting access using ropes, barricades, or other barr iers.**  # **Loads are not left suspended in the air. Raise the load only when it can be unloaded**  **at its destination.** # **Attempts are not made to catch or grab falling objects.** 2.16 Mechanical and Electrical Safety **Analytical Equipment The use and repair of analytical equipment can present unusual electri**  **cal and mechanical hazards. Before performing work on any piece of equipment:** 

# **Ensure that power has been disconnected from the unit.** # **Ensure that any reserve power (capacitors, batteries) are de-energized before working**  **on unit.** # **Do not remove any piece of equipment labelled "Trained Service Personnel Only"**

**. Call the appropriate service organization for repair of the unit.**  **Additional mechanical and electrical hazards may exist. Employ ees must be aware of all hazards**  **before performing any repair work. Employees should consult the cl ient's representative before**  **connecting transformers or other electrical lines to power suppl ies. See Lockout/Tagout procedures**  **in the Supplement of this manual. DEECO Health and Safety Plan Page 20 January 2010** 

2.17 New Employee Orientation **All new employees will undergo initial safety training which i ncludes assigned responsibilities, first**  **aid procedures (including bloodborne pathogens procedures), accident res ponse and reporting**  **procedures, emergency action plan and spill procedures, fire pr otection, general safety rules, and**  **housekeeping. Subsequent safety training will be provided based on job descr iption.** 

2.18 Power and Hand Tools **Improper use of power and hand tools can lead to serious injuries. Field personnel should be familiar**  **with the tools used and their operating manuals. Field personnel should ensure that:**

# **Tools are used for the propose for which they were designed.** # **Power tools must be either grounded or double-insulated.** # **Defective or damaged tools must be labelled and stored such that ot her employees**  **will not mistakenly use the tool.** # **Safety glasses with side shields or goggles must be worn when using power tools that**  **may produce projectiles.** 2.19 Process Safety Management **Many client locations will be required to provide DEECO (the cont ract employee) with process**  **safety management (PSM) information. The processes that requi re PSMs involves a flammable**  **liquid or gas (as defined in OSHA 1926.59(c)) on site in one location, in a quantity of 10,000 pounds**  **(4535.9 kg) or more except for hydrocarbon fuels used solely for workpla ce consumption as a fuel**  **(e.g., propane used for comfort heating, gasoline for vehicle refueling), if suc h fuels are not a part**  **of a process containing another highly hazardous chemical covered by t his standard and flammable**  **liquids stored in atmospheric tanks or transferred which are kept below their normal boiling point**  **without benefit of chilling or refrigeration. PSM describes th e procedures for preventing or**  **minimizing the consequences of catastrophic releases of toxic, r eactive, flammable, or explosive**  **chemicals. These releases may result in toxic, fire or explosion hazards The DEECO project manager/field team leader shall ensure t**  **hat all DEECO employees understand and follow these procedures.**  Management of Change **DEECO work activities at client’s facility may impact on the operation of a PSM regulated process.**  **The DEECO project manager/field team leader and the client’ s facility representative will perform**  **an initial process hazard analysis (hazard evaluation) on process es covered. The process hazard**  **analysis shall be appropriate to the complexity of the proce ss and shall identify, evaluate, and control**  **the hazards involved in the process as they relate to DEECO’s wor k activities. The client’s facility**  **representative shall determine and document the priority order for conducting process hazard**  **analyses based on a rationale which includes such considerations as extent of the process hazards,**  **number of potentially affected employees, age of the process, a nd operating history of the process.**  **The process hazard analysis must be conducted before any work by DEECO is c onducted.** **DEECO Health and Safety Plan Page 21 January 2010**

2.20 Scaffolding Scaffold Erection and Inspection **It is DEECO’s policy** not to **erect scaffolding. Scaffolding is typically the responsibi lity of the**  **client. Scaffolds shall be designed by a qualified person and s hall be constructed and loaded in**  **accordance with that design. Scaffolds shall be erected, moved, dismantled, or alt ered only under**  **the supervision and direction of a competent person qualified in scaf fold erection, moving,**  **dismantling or alteration. Such activities shall be performed only by experienced and trained**  **employees selected for such work by the competent person. Each day before using any scaffolding, ensure that the scaffolding ha**  **s been inspected by a person qualified in scaffold inspection.**  General Requirements for Scaffolding Use **1. The footing or anchorage for scaffolds shall be sound, rigid and c apable of carrying the**  **maximum intended load without settling or displacement. 2. Guardrails and toe-boards shall be installed on all open sides a**  **nd ends of scaffold platforms more than four feet above the ground or floor.**  **3. Scaffolds shall be provided with an access ladder or equivalent safe access**

**. 4. Employees shall not climb or work from scaffold handrails, mid-rails or brac**  **e members. 5. When free-standing manually propelled mobile scaffolds are u**  **sed, the height shall not exceed four times the minimum base dimension.**  **a.Employees shall not ride on mobile scaffolds when they are being moved. 6. All scaffolds shall be inspected by a competent person prior** **to use and shall be acceptance tagged.**  **7. Employees who erect scaffolds shall be trained in the proper means of b uilding scaffolds.**  **8. Employees using scaffolds shall be trained in the safe use of scaffolds. The project manager/field team leader must ensure that all**  **scaffolding is erected in accordance with OSHA regulations and the items listed above.**  **The project manager/field team leader must check with client 's representative to see if additional fall**  **protection is required when working on scaffolding.** Scaffold Use Training **DEECO shall have each employee who performs work while on a sc affold trained by a person**  **qualified in the subject matter to recognize the hazards associa ted with the type of scaffold being**  **used and to understand the procedures to control or minimize those hazards . The training shall**  **include the following areas, as applicable: 1. The nature of any electrical hazards, fall hazards and falling**  **object hazards in the work area; 2. The correct procedures for dealing with electrical hazards and**  **for erecting, maintaining, and disassembling the fall protection systems and falling object**  **protection systems being used; DEECO Health and Safety Plan Page 22 January 2010** 

**3. The proper use of the scaffold, and the proper handling of materials on the scaf fold; and**  **4. The maximum intended load and the load-carrying capacities of the scaffolds used. Additional training will be provided when changes in the types of sc**  **affolds, fall protection, falling object protection, or other equipment present a hazard about which an**  **employee has not been previously trained or when inadequacies in an affected employee's w**  **ork involving scaffolds indicate that the employee has not retained the requisite proficiency.**  2.21 Stairways and Ladders **With regards to stairways and ladders, employees should follow 29 C FR 1910.25, 26, and 27,**  **"Portable Wood Ladders, "Portable Metal Ladders, and Fixed Ladders" , and 1926 Subpart X,**  **"Stairways and Ladders". General Requirements**  **1. A stairway or ladder shall be provided at all personnel points of access where there is a break**  **in elevation of 19 inches or more, and no ramp, runway, sloped embankment or p ersonnel**  **hoist is provided. 2. A double-cleated ladder or two or more separate ladders shall**  **be provided when ladders are the only means of access or egress from a working area for 25 or**  **more employees, or when the ladder is to serve simultaneous two-way traffic.**  **3. When a building or structure has only one point of access between l evels, that point of access**  **shall be kept clear to permit free passage of employees. Stairways**  **1. Stairways that will not be a permanent part of the structur e on which construction work is**  **being performed shall have landings of not less than 30 inches in the di rection of travel and**  **extend at least 22 inches in width at every 12 feet or less of vertical rise. 2. Riser height and tread depth shall be uniform within each flight of stairs.**  **3. Where doors or gates open directly on a stairway, a platform shall be provided, and the swing**  **of the door shall not reduce the effective width of the platform to less than 20 inches. 4. Slippery conditions on stairways shall be eliminated before the sta**  **irways are used to reach other levels.**  **5. Except during stairway construction, foot traffic shall be prohi bited on skeleton metal stairs**  **where the treads and landings are to be filled in at a later da te, unless the stairs are fitted with**  **secured temporary treads and landings long enough to cover the entire t read and landing area.**  **6. Stairways having four or more risers or rising more than 30 inches , whichever is less, shall**  **be equipped with at least one handrail and one system along each unpr otected side or edge.**  **7. Stairrails shall be not less than 36 inches from the upper surf ace of the strairrail system to the**  **surface of the tread. 8. Mid-rails, screens, mesh, intermediate vertical me**  **mbers, or equivalent intermediate structural members, shall be provided between the top rail of the stair**  **rail system and the stair\way steps.** **DEECO Health and Safety Plan Page 23 January 2010**

**9. Handrails and the top rails of stairrail systems shall be capable of withstanding a force of at**  **least 200 pounds applied within two inches of the top edge, in any dow nward or outward**  **direction, at any point along the top edge. 10. Fixed stairways shall conform to the requirements of 29 CFR 1919.24**  **"Fixed Industrial Stairs".**  **Ladders 1. Portable ladders shall be capable of supporting at least f**  **our times the maximum intended load.**  **2. Portable metal or conductive ladders shall not be used near energi zed lines or equipment**  **except as may be necessary in specialized work such as high voltage substations where non**  **conductive ladders might present a greater hazard than conductive ladders. Conductive or**  **metal ladders shall be prominently marked a conductive and all nece ssary precautions shall**  **be taken when used in specialized work. 3. Ladder rungs, cleats and steps shall be parallel, level and unif**  **ormly spaced when the ladder is in position for use.**  **4. The minimum clear distance between side rails for all porta ble ladders shall be 11.5 inches.**  **5. The following requirements apply to the use of all ladders, including job-made la dders.**  **a. Ladders used for access to an upper landing surface, shall have s ide rails that extend**  **at least three feet above the landing surface. b. Ladders shall be maintained free of oil, grease and other slipping hazards.**  **c. Ladders shall be used only for the purpose for which they were designed. d. Non-self-supporting ladders shall be used at an angle such that t**  **he horizontal distance from the top support to the foot of the ladder is approxima**  **tely one-quarter of the working length of the ladder.**  **e. Non-self-supporting ladders shall be tied off or otherwise sec ured to prevent**  **accidental displacement. f. When ascending or descending a ladder, the user shall face the ladde**  **r and shall use at least one hand to grasp the ladder. The user shall not carry a**  **ny object or load that could cause him/her to lose balance and fall.**  **6. Ladders with structural defects, such as broken or missing rungs, shall be tagged DO NOT**  **USE, and shall be withdrawn from service. 7. Ladders will be inspected by a competent person and approved for**  **use before being put into service. Each user shall visually inspect ladder before using.**  **8. Ladders placed in any location where they can be displaced by w orkplace activities or traffic,**  **shall have warning signs posted. Extension Ladders**  **1. After the extension section has been raised to desired height, th e safety latches must be**  **engaged and the extension rope secured to a rung on the base section of the ladder before use.**  **2. Extension ladder sections are not to be used separately. Stepladders**  **1. Must be set level on all four feet, with spreaders locked on pla ce. Do not use as a straight**  **ladder. DEECO Health and Safety Plan Page 24 January 2010** 

**2. When used close to the edge of an elevated platform, roof or floor op ening, and when**  **location requirements so specify, they must be tied off, and employ ees using such a**  **stepladder shall wear fall-arresting equipment. 3. Employees using stepladders shall stand so that their waists**  **are below the top of the ladder. The President shall ensure that all employees are trained in the proper use**  **of ladders.** 2.22 Travel Safety **When driving any DEECO vehicle, or when driving your own personal vehicle when performing**  **DEECO related work, employees must:**

# **Obey all traffic rules and regulations.** # **Obey all traffic rules on a plant site.** # **Turn off vehicle and set brake when leaving vehicle.** # **Use horn at blind driveways or intersections with an obstructive view.** # **Have a valid North Carolina license to operate a DEECO vehicle and trailer.** # **Never pick up hitchhikers.** # **Perform a pre-trip check of vehicle(s) lights, horns, brakes, oil, etc.**

2.23 Thermal Stress **Thermal stress to the body can be caused when the body temperatur e is not in balance between body**  **heat production and heat loss to the surrounding environment. Heat stress is caused when the body**  **is unable to sufficiently cool the body, and cold stress is possibl e when the body is unable to**  **sufficiently heat the body.**

Heat Stress **Heat stress is a general term used to describe various degre es of heat illness. The temperature of the**  **body is a function of the amount of heat it produces and the amount of heat it can los e. When the**  **temperature of the environment approaches the body temperature, it becomes increasingly difficult**  **for the body to lose heat. Heat illness is possible when the body is not able to sufficiently cool itself.**  **The body can lose heat to the environment by three mechanisms. The m ost important is convection.**  **This is when the temperature of the skin is higher than that of the surrounding atmosphere.**  **Conduction is the transfer of heat from the body to a solid or liquid. An example would be the**  **immediate cooling of your face on a hot day by splashing cold wa ter on it. Both convection and**  **conduction can also be negative, meaning that if the atmosphere or ma terial in contact with the body**  **is warmer than the body itself, heat can be transferred to the body. The third, and comparably small, mechanism is respiration. This**  **is the warming and saturation of respired air while in the lungs.** 

Effects of Heat **The body possesses two physiological responses which enable it t o lose heat. The first is the dilation**  **(enlargement) of the blood vessels near the skin surface. This incr eases the flow of blood,**  **transferring heat to the skin. The skin temperature will increa se, and is cooled by either convection**  **on conduction. DEECO Health and Safety Plan Page 25 January 2010** 

**The second response is sweating. Sweating occurs when the increas e in blood flow to the skin does**  **not achieve the desired cooling effect. Heat is lost when sweat is evaporated from the body.** 

Heat Illness **Heat illness can be caused by either elevated body or skin temp eratures. Elevated body temperatures**  **can result in heat exhaustion, heat cramps, and heat stroke. Elevated skin temperatures can cause**  **skin-tissue damage.**

Heat Exhaustion **Heat exhaustion is caused by circulatory failure, where the amount of blood returned to the heart is**  **significantly reduced. Symptoms of heat exhaustion are fatigue, he adache, dizziness, loss of**  **appetite, nausea, abdominal pain, vomiting, shortness of breath, and puls e rates in excess of 150**  **beats per minute. Heat exhaustion can result in poor judgement, irri tability, and possibly fainting.**  **A person suffering from heat exhaustion can usually recover very quic kly if he/she is removed to a**  **cool place and allowed to lie down.** Heat Cramps **Heat cramps are muscle spasms which usually occur in the arm s, legs, back and abdomen. This is**  **due to excessive loss of salt from sweating. Heat cramps ca n be prevented by taking extra salt when**  **heavy work is carried out. It is recommended that employees do not take salt tablets, but rather**  **ensure that they eat at regular intervals during the course of the work, Extra salt can by added to the**  **body through eating.**

Heat Stroke **The most serious heat illness is heat stroke. When the body tem perature reaches a certain level,**  **sweating may stop. This will cause the body temperature to increase to critical levels. Such an**  **increase in body temperature can cause denaturization of proteins, enzyme degradation, changes in**  **the viscosity of cell protoplasm, and alterations in the physica l structure of the cell membranes.**  **Tissue damage and death are possible. Immediate medical attention is necessary for individuals sufferi**  **ng from heat stroke in order to avoid irreversible damage to the brain. The individual should be wrapped i**  **n cool, wet sheets. Immersion in a cold bath is not recommended, since a too rapid decrease in the**  **body temperature may result in tissue damage.** 

Precautions **1. Water intake must equal the amount of water lost due to sweat ing and excretion. In hot**  **environments, water intake must be forced since the body's normal thi rst mechanism is not**  **adequate to force the individual to drink. Continuous sweat rates of 1 to 2 liter s per hours**  **are not unusual. 2. Salt is lost during sweating. Additions of small amounts of salt to food may be nece**  **ssary. 3. Most importantly, frequent, short breaks during strenuous activities**  **allows the body to better adapt to the hot environment than infrequent long breaks. By taking shorte**  **r breaks, there is less cumulative fatigue and less demand on the heart and respiration.**  **4. It is possible for the body to acclimatize to hot environments. This may happen only if**  **successive days are spent in the hot environment (usually between 4 to 7). DEECO Health and Safety Plan Page 26 January 2010** 

Cold Stress **In cold environments, the body must increase its metabolic heat pro duction. In general, -30**  E **F is the lower limit for prolonged work. Unlike hot environments, individuals do**  **not acclimatize (physiologically adapt) to cold environments.**  **The wind-chill temperature, rather than the ambient temperature , best describe a cold environment.**  **Wind velocity adds to the rate of body cooling.**

Cold Illness Hypothermia **Hypothermia is a general cooling of the body temperature. Hypot hermia can occur in environments**  **above 32** E **F. Symptoms include excessive shivering, and numbness in extremiti es. The individual**  **should be moved to a warm environment. Alcohol should not be consumed, since t his will cause**  **the blood vessel to dilate, resulting in excessive body heat loss. Hot, non-alcoholic beverages should**  **be administered.**

Frost Bite **Frost bite can be either superficial or can penetrate be low the skin. Superficial frost bite can be**  **easily treated by warming the exposed skin with hands or other wa rmer part of the body (e.g. placing**  **hands under armpits). This will gradually warm the skin. Rapid w arming (exposure to fire, soaking**  **in cold water etc.) is not recommended since damage to the skin tis sue can occur. It is important to**  **note that pain will occur as the skin is thawed. When frost bite extends below the surface of the skin (from prolonged exposure**  **), it is essential to get immediate medical attention.** 

Precautions **1. Individuals should eat balanced meals and replace body liquids regula rly. Dehydration is as**  **prevalent in cold environments as it is in hot environments. Warm li quids are preferable**  **since they do not have to be warmed by the body after being consumed. 2. Proper protective clothing should be worn when exposed to cold environments.**  **3 Dexterity and judgement are both diminished in cold environments.** 2.24 Welding and Cutting **DEECO employees shall not perform any welding or cutting on a p roject site. The project**  **manager/field team leader shall ensure that the client contrac ts such work with qualified individuals.**  **DEECO employees shall leave the immediate area during any welding or cutting operations.**  2.26 Lockout/Tagout (LOTO) **Lockout/Tagout (LOTO) refers to specific practices and procedur es to safeguard employees from**  **the unexpected energization or startup of machinery and equipme nt, or the release of hazardous**  **energy during service or maintenance activities.** Under no circumstance should DEECO employee’s participate in LOTO **. Should any LOTO be necessary at a client’s facility, all LOTO**  **procedures are to be handled by the client or their representative. DEECO Health and Safety Plan Page 27 January 2010** 

2.27 Fall Protection 2.27.1 Determining When Fall Protection Must be Provided **DEECO shall determine if the walking/working surfaces on which it s employees are to work have**  **the strength and structural integrity to support employees safe ly. Employees shall be allowed to work**  **on those surfaces only when the surfaces have the requisite strength and structural int egrity.**  **Each employee on a walking/working surface (horizontal and vertical surface) with an unprotected**  **side or edge which is 6 feet (1.8 m) or more above a lower level shall be prot ected from falling by**  **the use of guardrail systems, safety net systems, or personal fall arres t systems.**  Hoist Areas **Each employee in a hoist area shall be protected from falling 6 feet (1.8 m) or more to lower levels**  **by guardrail systems or personal fall arrest systems. If guardrail systems, [or chain, gate, or guardrail]**  **or portions thereof, are removed to facilitate the hoisting ope ration (e.g., during landing of**  **materials), and an employee must lean through the access opening or out over the edge of the access**  **opening (to receive or guide equipment and materials, for example ), that employee shall be protected**  **from fall hazards by a personal fall arrest system.**

Holes **Each employee on walking/working surfaces shall be protecte d from falling through holes (including**  **skylights) more than 6 feet (1.8 m) above lower levels, by persona l fall arrest systems, covers, or**  **guardrail systems erected around such holes. Each employee on a walking/working surface shall be protected fr**  **om tripping in or stepping into or through holes (including skylights) by covers.**  **Each employee on a walking/working surface shall be protected fr om objects falling through holes**  **(including skylights) by covers.** Formwork and Reinforcing Steel **Each employee working on the face of formwork or reinforcing steel shall be protected from falling**  **6 feet (1.8 m) or more to lower levels by personal fall arrest systems, safety net systems, or**  **positioning device systems.** Ramps, Runways, and Other Walkways **Each employee on ramps, runways, and other walkways shall be protected from falling 6 feet (1.8**  **m) or more to lower levels by guardrail systems. DEECO Health and Safety Plan Page 28 January 2010** 

Excavations **Each employee at the edge of an excavation 6 feet (1.8 m) or more in depth shall be protected from**  **falling by guardrail systems, fences, or barricades when the e xcavations are not readily seen because**  **of plant growth or other visual barrier. Each employee at the edge of a well, pit, shaft, and similar e**  **xcavation 6 feet (1.8 m) or more in depth shall be protected from falling by guardrail systems, fences, barr**  **icades, or covers.** Dangerous Equipment **Each employee less than 6 feet (1.8 m) above dangerous equipment shal l be protected from falling**  **into or onto the dangerous equipment by guardrail systems or by equipment guards. Each employee 6 feet (1.8 m) or more above dangerous equipment shall**  **be protected from fall hazards by guardrail systems, personal fall arrest systems, or safe**  **ty net systems.** Overhand Bricklaying and Related Work **Currently, DEECO does not perform overhand bricklaying, so any fall p rotection programs related**  **to overhand brick are not applicable.** Working on Roofs **Each employee engaged in any activities on low-slope roofs (slo pe less than 4 in 12), with**  **unprotected sides and edges 6 feet (1.8 m) or more above lower level s shall be protected from falling**  **by guardrail systems, safety net systems, personal fall arres t systems, or a combination of warning**  **line system and guardrail system, warning line system and safe ty net system, or warning line system**  **and personal fall arrest system, or warning line system and safety monitori ng system.**  **Each employee on a steep roof (slope greater than 4 in 12) with unprotected sides and edges 6 feet**  **(1.8 m) or more above lower levels shall be protected from fa lling by guardrail systems with**  **toeboards, safety net systems, or personal fall arrest systems.**

Precast Concrete Erection **Currently, DEECO does not perform precast concrete erection, so a ny fall protection programs**  **related to precast concrete erection are not applicable.**

Residential Construction **Currently, DEECO does not perform residential construction, so any fa ll protection programs related**  **to residential construction are not applicable. DEECO Health and Safety Plan Page 29 January 2010** 

Wall Openings **Each employee working on, at, above, or near wall openings (including t hose with chutes attached)**  **where the outside bottom edge of the wall opening is 6 feet (1.8 m) or more above lower levels and**  **the inside bottom edge of the wall opening is less than 39 inches ( 1.0 m) above the walking/working**  **surface, shall be protected from falling by the use of a guar drail system, a safety net system, or a**  **personal fall arrest system.** Walking/Working Surfaces Not Otherwise Addressed (e.g Man Lifts) **When operating or working on any man lifts that fall under the ANS I standard definition that**  **includes certain vehicle-mounted elevating and rotating work platforms , namely "extensible boom**  **platforms," "aerial ladders," "articulating boom platforms," " vertical towers," and "a combination**  **of any of the above.", DEECO employees shall be protected from f alling by a personal fall arrest**  **system. For all other walking/working surfaces not otherwise addressed, each**  **employee on a walking/working surface 6 feet (1.8 m) or more above lower levels shall be**  **protected from falling by a guardrail system, safety net system, or personal fall arrest sys**  **tem.** Protection from Falling Objects **When an employee is exposed to falling objects, the employer sha ll have each employee wear a hard**  **hat and shall erect toeboards, screens, or guardrail systems to p revent objects from falling from**  **higher levels, erect a canopy structure and keep potential fall objects far enough from the edge of the**  **higher level so that those objects would not go over the edge if they were accidentally displaced; or,**  **barricade the area to which objects could fall, prohibit employe es from entering the barricaded area,**  **and keep objects that may fall far enough away from the edge of a higher level so that those objects**  **would not go over the edge if they were accidentally displaced. The project manager/field team leader must check with clien**  **t's representative to see if additional barricade procedures specific to their facility are required.**  2.27.2 Guidelines for Fall Protection **The DEECO project manager/field team in conjunction with the client's representative shall**  **determine when additional fall protection is required. The client shall provide and install all Guard Rail Systems, Sa**  **fety Net Systems, Positioning Device Systems and Warning Line Systems required for DEECO an employ**  **ee, and shall comply with all other pertinent requirements of described below before that empl**  **oyee begins the work that necessitates the fall protection.**  Guardrail Systems **Top edge height of top rails, or equivalent guardrail system me mbers, shall be 42 inches (1.1 m) plus**  **or minus 3 inches (8 cm) above the walking/working level. When conditions w arrant, the height of** **DEECO Health and Safety Plan Page 30 January 2010**

**the top edge may exceed the 45-inch height, provided the guardrail system meets all other criteria**  **of this paragraph. Note: When employees are using stilts, the top edge height of t**  **he top rail, or equivalent member, shall be increased an amount equal to the height of the stilts.**  **Midrails, screens, mesh, intermediate vertical members, or equiva lent intermediate structural**  **members shall be installed between the top edge of the guardrail s ystem and the walking/working**  **surface when there is no wall or parapet wall at least 21 inches (53 cm) high. Midrails, when used, shall be installed at a height midway be**  **tween the top edge of the guardrail system and the walking/working level.**  **Screens and mesh, when used, shall extend from the top rail to the w alking/working level and along**  **the entire opening between top rail supports. Intermediate members (such as balusters), when used between p**  **osts, shall be not more than 19 inches (48 cm) apart.**  **Other structural members (such as additional midrails and archit ectural panels) shall be installed**  **such that there are no openings in the guardrail system that are more than 19 inches (.5 m ) wide.**  **Guardrail systems shall be capable of withstanding, without failure, a f orce of at least 200 pounds**  **(890 N) applied within 2 inches (5.1 cm) of the top edge, in any outward or downward direction, at**  **any point along the top edge. When the 200 pound (890 N) test load specified above is applied in a downwa**  **rd direction, the top edge of the guardrail shall not deflect to a height less than 39 inc**  **hes (1.0 m) above the walking/working level.**  **Midrails, screens, mesh, intermediate vertical members, solid p anels, and equivalent structural**  **members shall be capable of withstanding, without failure, a f orce of at least 150 pounds (666 N)**  **applied in any downward or outward direction at any point along the midrail or other membe r.**  **Guardrail systems shall be so surfaced as to prevent injury to an employee from punctures or**  **lacerations, and to prevent snagging of clothing. The ends of all top rails and midrails shall not overhang the term**  **inal posts, except where such overhang does not constitute a projection hazard.**  **Steel banding and plastic banding shall not be used as top rails or midrail s.**  **Top rails and midrails shall be at least one-quarter inch (0.6 cm) nominal diam eter or thickness to**  **prevent cuts and lacerations. If wire rope is used for top rai ls, it shall be flagged at not more than 6-**  **foot intervals with high-visibility material. When guardrail systems are used at hoisting areas, a chain, gate**  **or removable guardrail section shall be placed across the access opening between guardrail sect**  **ions when hoisting operations are not taking place.** **DEECO Health and Safety Plan Page 31 January 2010**

**When guardrail systems are used at holes, they shall be erecte d on all unprotected sides or edges of**  **the hole. When guardrail systems are used around holes used for the passage of**  **materials, the hole shall have not more than two sides provided with removable guardrail sections to**  **allow the passage of materials. When the hole is not in use, it shall be closed over wit**  **h a cover, or a guardrail system shall be provided along all unprotected sides or edges.**  **When guardrail systems are used around holes which are used as poi nts of access (such as**  **ladderways), they shall be provided with a gate, or be so offset that a person cannot walk directly into**  **the hole. Guardrail systems used on ramps and runways shall be erected al**  **ong each unprotected side or edge. Manila, plastic or synthetic rope being used for top rails or**  **midrails shall be inspected as frequently as necessary to ensure that it continues to meet the strength re**  **quirements of paragraph (b)(3) of this section.**  Safety Net Systems **Safety nets shall be installed as close as practicable unde r the walking/working surface on which**  **employees are working, but in no case more than 30 feet (9.1 m) below such le vel. When nets are**  **used on bridges, the potential fall area from the walking/wor king surface to the net shall be**  **unobstructed. Safety nets shall extend outward from the outermost projection of the work surfac**  **e as follows: Vertical distance from working level to**  **horizontal plane of net Minimum required horizontal distance of**  **outer edge of net from the edge of the**

**working surface Up to 5 feet 8 feet**  **More than 5 feet up to 10 feet 10 feet More than 10 feet 13 feet**  **Safety nets shall be installed with sufficient clearance under them to prevent contact with the surface**  **or structures below when subjected to an impact force equal to the drop test described below. Safety**  **nets and their installations shall be capable of absorbing an i mpact force equal to that produced by**  **the drop test described below. Except as described below, safety nets and safety net instal**  **lations shall be drop-tested at the jobsite after initial installation and before being used as a fall pr**  **otection system, whenever relocated, after major repair, and at 6-month intervals if left in one place. The dr**  **op-test shall consist of a 400 pound (180 kg) bag of sand 30 + or - 2 inches (76 + or - 5 cm) in diameter dropped i**  **nto the net from the highest walking/working surface at which employees are exposed t**  **o fall hazards, but not from less than 42 inches (1.1 m) above that level.** **DEECO Health and Safety Plan Page 32 January 2010**

**When the employer can demonstrate that it is unreasonable to perform the drop-test, the employer**  **(or a designated competent person) shall certify that the net a nd net installation is in compliance with**  **the provisions of paragraphs (c)(3) and (c)(4)(i) of this secti on by preparing a certification record**  **prior to the net being used as a fall protection system. The c ertification record must include an**  **identification of the net and net installation for which the certifi cation record is being prepared; the**  **date that it was determined that the identified net and net instal lation were in compliance with**  **paragraph (c)(3) of this section and the signature of the person m aking the determination and**  **certification. The most recent certification record for each net and net installation shall be available**  **at the jobsite for inspection. Defective nets shall not be used. Safety nets shall be inspect**  **ed at least once a week for wear, damage, and other deterioration. Defective components shall be removed**  **from service. Safety nets shall also be inspected after any occurrence which could affect**  **the integrity of the safety net system. Materials, scrap pieces, equipment, and tools which have fallen int**  **o the safety net shall be removed as soon as possible from the net and at least before the next work shift.**  **The maximum size of each safety net mesh opening shall not exc eed 36 square inches (230 cm) nor**  **be longer than 6 inches (15 cm) on any side, and the opening, measur ed center-to-center of mesh**  **ropes or webbing, shall not be longer than 6 inches (15 cm). All mes h crossings shall be secured to**  **prevent enlargement of the mesh opening. Each safety net (or section of it) shall have a border rope f**  **or webbing with a minimum breaking strength of 5,000 pounds (22.2 kN).**  **Connections between safety net panels shall be as strong as int egral net components and shall be**  **spaced not more than 6 inches (15 cm) apart.** Personal Fall Arrest Systems **Personal fall arrest systems shall consist of a full body har ness. Body belts are not acceptable as part**  **of a personal fall arrest system except in a positioning device system as described below.**  **Connectors shall be drop forged, pressed or formed steel, or made of equivalent materials and shall**  **have a corrosion-resistant finish. All surfaces and edges sha ll be smooth to prevent damage to**  **interfacing parts of the system. Dee-rings and snaphooks shall have a minimum tensile strength of 5,000 pounds**  **(22.2 kN) and shall be proof-tested to a minimum tensile load of 3,600 pounds (16 kN) without cra**  **cking, breaking, or taking permanent deformation.**  **Snaphooks shall be sized to be compatible with the member to whi ch they are connected to prevent**  **unintentional disengagement of the snaphook by depression of the snaphoo k keeper by the connected**  **member, or shall be a locking type snaphook designed and used to prev ent disengagement of the**  **snaphook by the contact of the snaphook keeper by the connected mem ber. Only locking type**  **snaphooks shall be used. DEECO Health and Safety Plan Page 33 January 2010** 

**Unless the snaphook is a locking type and designed for the following conne ctions, snaphooks shall**  **not be engaged directly to webbing, rope or wire rope, to each ot her, to a dee-ring to which another**  **snaphook or other connector is attached, to a horizontal lifeline; or to a ny object which is**  **incompatibly shaped or dimensioned in relation to the snaphook such that unintentional**  **disengagement could occur by the connected object being able to depr ess the snaphook keeper and**  **release itself. On suspended scaffolds or similar work platforms with horizontal l**  **ifelines which may become vertical lifelines, the devices used to connect to a horizontal lifeline shal**  **l be capable of locking in both directions on the lifeline. Horizontal lifelines shall be des**  **igned, installed, and used, under the supervision of a qualified person, as part of a complete personal**  **fall arrest system, which maintains a safety factor of at least two.**  **Lanyards and vertical lifelines shall have a minimum breaking st rength of 5,000 pounds (22.2 kN).**  **Lifelines shall be protected against being cut or abraded. Se lf-retracting lifelines and lanyards which**  **automatically limit free fall distance to 2 feet (0.61 m) or less shall be capable of sustaining a**  **minimum tensile load of 3,000 pounds (13.3 kN) applied to the device with the lifeline or lanya rd**  **in the fully extended position. Self-retracting lifelines and lanyards which do not limit free**  **fall distance to 2 feet (0.61 m) or less, ripstitch lanyards, and tearing and deforming lanyards shall be ca**  **pable of sustaining a minimum tensile load of 5,000 pounds (22.2 kN) applied to the device with the lifeli**  **ne or lanyard in the fully extended position.**  **Ropes and straps (webbing) used in lanyards, lifelines, and streng th components of body belts and**  **body harnesses shall be made from synthetic fibers. Anchorages used for attachment of personal fall arrest equipment**  **shall be independent of any anchorage being used to support or suspend platforms and capable of**  **supporting at least 5,000 pounds (22.2 kN) per employee attached, or shall be designed, install**  **ed, and used as part of a complete personal fall arrest system which maintains a saf**  **ety factor of at least two and under the supervision of a qualified person.**  **Personal fall arrest systems, when stopping a fall, shall limit maximum arresting force on an**  **employee to 900 pounds (4 kN) when used with a body belt, limit maximum arresting force on an**  **employee to 1,800 pounds (8 kN) when used with a body harness, be rigged s uch that an employee**  **can neither free fall more than 6 feet (1.8 m), nor contact any lower level, bring an employee to a**  **complete stop and limit maximum deceleration distance an emp loyee travels to 3.5 feet (1.07 m)**  **and, have sufficient strength to withstand twice the potential impa ct energy of an employee free**  **falling a distance of 6 feet (1.8 m), or the free fall distance permitted by the system, whichever is**  **less. The attachment point of the body belt shall be located in the cen**  **ter of the wearer's back. The attachment point of the body harness shall be located in the center**  **of the wearer's back near shoulder level, or above the wearer's head.**  **Body belts, harnesses, and components shall be used only for employee protection (as part of a**  **personal fall arrest system or positioning device system) and not to hoist mat erials.** **DEECO Health and Safety Plan Page 34 January 2010**

**Personal fall arrest systems and components subjected to imp act loading shall be immediately**  **removed from service and shall not be used again for employee prot ection until inspected and**  **determined by a competent person to be undamaged and suitable for reuse. The employer shall provide for prompt rescue of employees in the**  **event of a fall or shall assure that employees are able to rescue themselves.**  **Personal fall arrest systems shall be inspected prior to e ach use for wear, damage and other**  **deterioration, and defective components shall be removed from service. Body belts shall be at least one and five-eighths (1 5/8) inches (4.1 cm) wide.**  **Personal fall arrest systems shall not be attached to guardra il systems, nor shall they be attached to**  **hoists. When a personal fall arrest system is used at hoist a reas, it shall be rigged to allow the**  **movement of the employee only as far as the edge of the walking/working surface.** Positioning Device Systems **Positioning device systems shall be rigged such that an employee cannot free fall more than 2 feet**  **(.9 m). Positioning devices shall be secured to an anchorage capabl e of supporting at least twice the**  **potential impact load of an employee's fall or 3,000 pounds (13.3 kN), whichever is great er.**  **Connectors shall be drop forged, pressed or formed steel, or made of equivalent materials and shall**  **have a corrosion-resistant finish. All surfaces and edges shall be smooth to prevent damage to**  **interfacing parts of this system. Connecting assemblies shall have a minimum tensile strength of**  **5,000 pounds (22.2 kN). Dee-rings and snaphooks shall be proof-tested to a minimum tensile**  **load of 3,600 pounds (16 kN) without cracking, breaking, or taking permanent deformation.**  **Snaphooks shall be sized to be compatible with the member to whi ch they are connected to prevent**  **unintentional disengagement of the snaphook by depression of the snaphook keeper by the connected**  **member, or shall be a locking type snaphook designed and used to preven t disengagement of the**  **snaphook by the contact of the snaphook keeper by the connected member. A s of January 1, 1998,**  **only locking type snaphooks shall be used. Unless the snaphook is a locking type and designed for the following conne**  **ctions, snaphooks shall not be engaged directly to webbing, rope or wire rope, to each ot**  **her, to a dee-ring to which another snaphook or other connector is attached, to a horizontal lifeline;**  **or to any object which is incompatibly shaped or dimensioned in relation to the snaphook such t**  **hat unintentional disengagement could occur by the connected object being able to depr**  **ess the snaphook keeper and release itself.**  **Positioning device systems shall be inspected prior to each use for wear, damage, and other**  **deterioration, and defective components shall be removed from service. Body belts, harnesses, and components shall be used only for employee**  **protection (as part of a personal fall arrest system or positioning device system) and not to hoist mat**  **erials. DEECO Health and Safety Plan Page 35 January 2010** 

Warning Line Systems **Warning line systems shall be erected around all sides of the r oof work area. When mechanical**  **equipment is not being used, the warning line shall be erected not l ess than 6 feet (1.8 m) from the**  **roof edge. When mechanical equipment is being used, the warning line shall be erected not less than**  **6 feet (1.8 m) from the roof edge which is parallel to the direct ion of mechanical equipment**  **operation, and not less than 10 feet (3.1 m) from the roof edge which is perpendicular to the direction**  **of mechanical equipment operation. Points of access, materials handling areas, storage areas, and hoi**  **sting areas shall be connected to the work area by an access path formed by two warning lines. When t**  **he path to a point of access is not in use, a rope, wire, chain, or other barricade, equivalent in strengt**  **h and height to the warning line, shall be placed across the path at the point where the path int**  **ersects the warning line erected around the work area, or the path shall be offset such that a person cannot**  **walk directly into the work area. Warning lines shall consist of ropes, wires, or chains, and supporti**  **ng stanchions erected as follows: 1. The rope, wire, or chain shall be flagged at not more than 6-foot**  **(1.8 m) intervals with high visibility material;**  **2. The rope, wire, or chain shall be rigged and supported in such a w ay that its lowest point**  **(including sag) is no less than 34 inches (.9 m) from the walking/worki ng surface and its**  **highest point is no more than 39 inches (1.0 m) from the walking/working surface; 3. After being erected, with the rope, wire, or chain attached**  **, stanchions shall be capable of resisting, without tipping over, a force of at least 16 pounds (71**  **N) applied horizontally against the stanchion, 30 inches (.8 m) above the walking/working surface**  **, perpendicular to the warning line, and in the direction of the floor, roof, or platform edge;**  **4. The rope, wire, or chain shall have a minimum tensile strength of 500 pounds (2.22 kN), and**  **after being attached to the stanchions, shall be capable of sup porting, without breaking, the**  **loads applied to the stanchions as described above; and 5. The line shall be attached at each stanchion in such a way that**  **pulling on one section of the line between stanchions will not result in slack being taken up i**  **n adjacent sections before the stanchion tips over.**  **No employee shall be allowed in the area between a roof edge a nd a warning line unless the**  **employee is performing roofing work in that area. Mechanical equipment on roofs shall be used or stored only in areas w**  **here employees are protected by a warning line system, guardrail system, or personal fall arrest sys**  **tem.** Controlled Access Zone **When used to control access to areas where leading edge and other opera tions are taking place the**  **controlled access zone shall be defined by a control line or by any other means that restricts access.** **DEECO Health and Safety Plan Page 36 January 2010**

**When control lines are used, they shall be erected not less than 6 f eet (1.8 m) nor more than 25 feet**  **(7.7 m) from the unprotected or leading edge, except when erecting precast concrete members.**  **DEECO does not erecting precast concrete members. The control line shall extend along the entire**  **length of the unprotected or leading edge and shall be approximatel y parallel to the unprotected or**  **leading edge. The control line shall be connected on each side to a guardrail system or wall.**  **Additional control lines shall be erected at each end to enclose the controlled acce ss zone.**  **Control lines shall consist of ropes, wires, tapes, or equivalent m aterials, and supporting stanchions.**  **Each line shall be flagged or otherwise clearly marked at not more than 6-foot (1.8 m) intervals with**  **high-visibility material. Each line shall be rigged and suppor ted in such a way that its lowest point**  **(including sag) is not less than 39 inches (1 m) from the walking/wor king surface and its highest**  **point is not more than 45 inches (1.3 m) from the walking/working surface . Each line shall have a**  **minimum breaking strength of 200 pounds (.88 kN).** Safety Monitoring Systems **DEECO shall designate a competent person as the safety monitor . The safety monitor will monitor**  **the safety of other employees. The safety monitor shall be com petent to recognize fall hazards. The**  **safety monitor shall warn the employee when it appears that the employee is unaware of a fall hazard**  **or is acting in an unsafe manner. The safety monitor shall be on t he same walking/working surface**  **and within visual sighting distance of the employee being monitored. The safety moni tor shall be**  **close enough to communicate orally with the employee. The safety monitor shall not have other**  **responsibilities which could take the monitor's attention from the monitoring functi on.**  **Mechanical equipment shall not be used or stored in areas where sa fety monitoring systems are being**  **used to monitor employees engaged in roofing operations on low-slope roofs. No employee, other**  **than an employee engaged in roofing work [on low-sloped roofs] or an em ployee covered by a fall**  **protection plan, shall be allowed in an area where an employee i s being protected by a safety**  **monitoring system. Each employee working in a controlled access zone shall be direct**  **ed to comply promptly with fall hazard warnings from safety monitors.** 

Covers **Covers located in roadways and vehicular aisles shall be capable of supporting , without failure, at**  **least twice the maximum axle load of the largest vehicle ex pected to cross over the cover. All other**  **covers shall be capable of supporting, without failure, at leas t twice the weight of employees,**  **equipment, and materials that may be imposed on the cover at any one time. All covers shall be**  **secured when installed so as to prevent accidental displacement b y the wind, equipment, or**  **employees. All covers shall be color coded or they shall be ma rked with the word "HOLE" or**  **"COVER" to provide warning of the hazard.** Protection from Falling Objects **Toeboards, when used as falling object protection, shall be erected al ong the edge of the overhead**  **walking/working surface for a distance sufficient to protect employee s below. Toeboards shall be** **DEECO Health and Safety Plan Page 37 January 2010**

**capable of withstanding, without failure, a force of at least 50 pounds (222 N) applied in any**  **downward or outward direction at any point along the toeboard. Toeboards s hall be a minimum of**  **3 1/2 inches (9 cm) in vertical height from their top edge to the level of the walking/working surface.**  **They shall have not more than 1/4 inch (0.6 cm) clearance above the wal king/working surface. They**  **shall be solid or have openings not over 1 inch (2.5 cm) in greatest dimension. Where tools,**  **equipment, or materials are piled higher than the top edge of a toeboard, paneling or screening shall**  **be erected from the walking/working surface or toeboard to the top of a guardra il system's top rail**  **or midrail, for a distance sufficient to protect employees below. Guardrail systems, when used as**  **falling object protection, shall have all openings small enough to prevent passage of potential falling**  **objects. Canopies, when used as falling object protection, shall be strong**  **enough to prevent collapse and to prevent penetration by any objects which may fall onto the canopy.** 

Fall Protection Plan **This option is available only to employees engaged in leading edge work that it is infeasible or it**  **creates a greater hazard to use conventional fall protection equipment. The fall protection plan shall be prepared by a qualified per**  **son and developed specifically for the site where the leading edge work, precast concrete work, or residential constr**  **uction work is being performed and the plan must be maintained up to date. Any changes t**  **o the fall protection plan shall be approved by a qualified person. A copy of the fall protection**  **plan with all approved changes shall be maintained at the job site. The implementation of the fal**  **l protection plan shall be under the supervision of a competent person. The fall protection plan shall**  **document the reasons why the use of conventional fall protection systems (guardrail systems, pers**  **onal fall arrest systems, or safety nets systems) are infeasible or why their use would create a greater hazard.**  **The fall protection plan shall include a written discussion of ot her measures that will be taken to**  **reduce or eliminate the fall hazard for workers who cannot be provide d with protection from the**  **conventional fall protection systems. For example, the employer s hall discuss the extent to which**  **scaffolds, ladders, or vehicle mounted work platforms can be used to pr ovide a safer working surface**  **and thereby reduce the hazard of falling. The fall protection plan shall identify each location where convent**  **ional fall protection methods cannot be used. These locations shall then be classified as controll**  **ed access zones. Where no other alternative measure has been implemented, the employer shall**  **implement a safety monitoring system.**  **The fall protection plan must include a statement which provides the name or other method of**  **identification for each employee who is designated to work in cont rolled access zones. No other**  **employees may enter controlled access zones. In the event an employee falls, or some other related, serious inci**  **dent occurs, (e.g., a near miss) the employer shall investigate the circumstances of the fall or ot**  **her incident to determine if the fall protection plan needs to be changed (e.g. new practices, procedures,**  **or training) and shall implement those changes to prevent similar types of falls or incidents.** **DEECO Health and Safety Plan Page 38 January 2010**

2.27.3 Fall Protection Training Program **DEECO shall provide a training program for each employee who mi ght be exposed to fall hazards.**  **The program shall enable each employee to recognize the haza rds of falling and shall train each**  **employee in the procedures to be followed in order to minimize these hazards. DEECO shall assure that each employee has been trained, as**  **necessary, by a competent person qualified in the nature of fall hazards in the work area, the correc**  **t procedures for erecting, maintaining, disassembling, and inspecting the fall protection sy**  **stems to be used, the use and operation of guardrail systems, personal fall arrest system**  **s, safety net systems, warning line systems, safety monitoring systems, controlled access zones, and other protec**  **tion to be used, the role of each employee in the safety monitoring system when this system**  **is used, the limitations on the use of mechanical equipment during the performance of roofing work on low-slo**  **ped roofs, the correct procedures for the handling and storage of equipment and materials and**  **the erection of overhead protection; and the role of employees in fall protection plans.**  Certification of Training **DEECO shall verify compliance with the Fall Protection Training Program by preparing a written**  **certification record. The written certification record shall contain the na me or other identity of the**  **employee trained, the date(s) of the training, and the signature of the person who conducted the**  **training or the signature of the employer. If training is conducted b y another employer, the**  **certification record shall indicate the date the employer deter mined the prior training was adequate**  **rather than the date of actual training. The latest training certification shall be maintained.**  Retraining **When DEECO has reason to believe that any affected employee who has already been trained does**  **not have the understanding and skill required by the Fall Protection Tra ining Program, DEECO shall**  **retrain each such employee. Circumstances where retraining is required include, but are not limited**  **to, situations where changes in the workplace render previous traini ng obsolete, changes in the types**  **of fall protection systems or equipment to be used render previous training obsolete, or inadequacies**  **in an affected employee's knowledge or use of fall protection sys tems or equipment indicate that the**  **employee has not retained the requisite understanding or skill.** 2.28 Combustible Gas (LEL), Carbon Monoxide, Hydrogen Sulfide, and/or Oxygen Monitors **For safe operation around processes involving combustible material s, a hot work permit may be**  **required. Hot work permits (HWPs) are required for any process where testing activities may**  **produce an ignition source in a work area in which flammable vapors or gases may be present. To**  **issue an HWP, a hazard assessment must be performed. To do so, combus tible gas and vapor**  **concentrations must be determined for the work area and job classi fication in question, then**  **compared to acceptable standards. These surveys typically invol ve the use of combustible gas**  **meters-also called lower explosive limit (LEL) meters. The se surveys are conducted by the client**  **personnel issuing the hot work permits . DEECO Health and Safety Plan Page 39 January 2010** 

**To perform the surveys properly, the facility will have work i nstructions and standard operating**  **procedures (SOPs) developed, implemented and documented. Training in LEL instrument use,**  **instrument calibration, sampling strategy, continuous or follow-up monitor ing, tracking of denied**  **permits, communication between departments related to the content of processes, documentation of**  **results, auditing of hot work permit procedures and results, and the cont inuous improvement of those**  **SOPs will be addressed. In some cases DEECO will be required to provide additional monitori**  **ng for LEL, carbon monoxide, hydrogen sulfide, and/or oxygen. For these situations, DEECO personnel will be t**  **rained in LEL, carbon monoxide, hydrogen sulfide, and/or oxygen instrument use and instrument calibration.**  Training in Instrument Use **Thorough, documented training will be performed for the use of LEL, ca rbon monoxide, hydrogen**  **sulfide, and/or oxygen meters. Thus, training programs for operat ors of LEL, carbon monoxide,**  **hydrogen sulfide, and/or oxygen meters will include: 1. Work instructions for basic instrument use;**  **2. Theory of instrument operation; 3 Instrument maintenance and calibration; and**  **4. Recordkeeping for calibration and maintenance.**

Instrument Calibration **The instrument manufacturers detail procedures for calibrating LEL, c arbon monoxide, hydrogen**  **sulfide, and/or oxygen meters will be followed. Calibration includes; 1. Clean air-zero point calibration;**  **2. Calibration of response with the appropriate span gas; 3. Checking and calibration, for actively pumped meters, of the air flow rate in t**  **he system; 4. Fault detection and subsequent maintenance; and**  **5. Record keeping. Any decisions made to extend the period between calibrations or to**  **lessen the rigor of calibrations must first be formally evaluated by qualified persons against**  **the manufacturer's recommendations, industry best practices and governmental regulations. Requirements**  **for specified, periodic calibration of zero, span and flow are mandates, not recommendations. T**  **his applies for all systems, but is especially critical for systems used in environments w**  **here air contaminants that may degrade the meter's sensing element may be present.** **DEECO Health and Safety Plan Page 40 January 2010**

**For gases and vapors other than those for which a device was calibr ated, the manufacturer's**  **instructions and correction curves should be consult. Variations in re sponse that may result in**  **incorrect readings from such interferences as: 1. Oxygen concentration;**  **2. Gas pressure; 3. Sensor poisons (i.e., silicon, silicates and organic lead, acid g**  **ases) and sensor depressants (i.e., chlorinated hydrocarbons, acid gases); and**  **4. The fact that no reading will occur, or is even possible, for t he detection of combustible**  **airborne mists or dusts, such as lubricating oils, coal dust or grain dust. The portion of the calibration that deals with instrument airflow**  **rate must include the blocked flow alarm must being tested before and after each use. While this**  **is a requirement for all such systems, it is especially critical for instruments used in dusty environments.**  Sampling Strategy **Measurement of values for each atmospheric parameter should be m ade for at least the minimum**  **response time of the instrument. When monitoring operations involving a descent into atmospheres**  **that may be stratified, the atmospheric envelope should be tested a dista nce of approximately four**  **feet in the direction of travel and to each side. If a sampli ng probe is used, the rate of progress**  **should be slowed to accommodate the sampling speed and detector response . Any reading greater than zero should be followed by an assessment to:**  **1. Determine the source of the flammable vapors; 2. Eliminate the source, if possible; and**  **3. Ensure control of the source so that concentrations will not exceed ( at most) 10% of the LEL**  **at any location where it is possible that an ignition source may be present**

**.** Continuous or Follow-Up Monitoring **Continuous or follow-up monitoring may be required under conditions where the process, sequence**  **of work instructions or ambient conditions might reasonably be expec ted to change in a manner that**  **might increase the concentration of flammable gas or vapor. If conditions change during the course**  **of the permit period in a way that presents or could present ad ditional hazards, then work will be**  **terminated until the area or conditions are made safe and permit conditions are re -evaluated.**  **Processes that may affect the composition, concentration, flow ra te or volume, pressure and/or**  **temperature of flammable liquids, vapors or gases; 1. Processes adjacent to the process at which hot work is being performed;** **DEECO Health and Safety Plan Page 41 January 2010**

**2. Ambient conditions such as temperature, wind direction and wind speed; and 3. Other factors, such as the presence of uncontrolled vehicular traff**  **ic and/or ignition sources.** Documentation of Results (Record Keeping) **Each monitor obtained by DEECO will be assign a unique equipme nt identification (control) number**  **and complete records, including periodic performance, calibration and maintenance checks will be**  **maintained.** 2.29 Emergency Response/Evacuation Program **While at a client’s facility, follow their Emergency Respons e/Evacuation Program. The project**  **manager/field team leader will ensure that the employees a re aware of the facilities’ Emergency**  **Response/Evacuation Program. Their plan should address the following; 1. Procedures for reporting a fire or other emergency;**  **2. Procedures for emergency evacuation, including type of evacuation and e xit route**  **assignments; 3. Procedures to account for all employees after evacuation (head count);**  **4. Procedures to be followed by employees performing rescue or medical duti es; and**  **5. The name or job title of every employee who may be contacted by employees who need more**  **information about the plan or an explanation of their duties under the plan. Otherwise, when working at DEECO’s office, the following Emerge**  **ncy Response/Evacuation procedures should be followed;**  **1. Report a fires or other emergencies by dialing 911. Administer first aid and/or CPR if you**  **trained. Do not attempt to fight any fires unless you have been tr ained in the use of fire**  **extinguishers; 2. Should an evacuation be necessary follow the escape route assignme**  **nts. Exit diagrams are place throughout the office to identify the escape routes to be foll**  **owed by employees from each specific facility location. Assist in the evacuation of any visitors and cont**  **ractors; 3. Account for employees after the evacuation to ensure that everyone**  **got out. Designated employees will sweep areas, checking offices and rest rooms, b**  **efore being the last to leave a workplace or conducting a roll call in the assembly area; and**  **4. Account for any visitors and contractors using the Visitors and Contractors Sign In Log**

**. DEECO Health and Safety Plan Page 42 January 2010** 

2.30 Compressed Air Systems **DEECO employees are not allowed to operate pneumatic powe r tools or use the compressed air**  **systems, air hoses, or air lines associated with pneumatic power tools.**

2.31 Concrete Construction **DEECO employees are not allowed perform any concrete work, as described in OS HA 1926.700-**  **706.**

2.32 Powder-Actuated Tools **DEECO employees are not allowed to use powder-actuated tools, as described in OSHA 1926.302**  **(e). DEECO Health and Safety Plan Page 43 January 2010** 



### 3.0 Chemical Safety Guidelines **The procedures and guidelines detailed in the following sections are to be used by DEECO Field**  **personnel while performing work on either DEECO or client premis es. If the client has additional**  **safety procedures, Field personnel are to follow the procedures whi ch are more stringent. In all**  **cases, all OSHA and/or EPA requirements shall be met. Field personnel are to refer to the Material Safety Data S**  **heet and chemical labels for specific procedures and handling requirements. Copies of MSDSs for each chem**  **ical used, as well as for each chemical Field personnel may be exposed to while on a client's site, must b**  **e made available. The client is responsible for ensuring that MSDSs for chemicals us**  **ed on the work site are available for review. All Field personnel should refer to these MSDSs and be**  **familiar with the properties and handling requirements of all chemicals that may be used or encountered.**  **The required level of personal protective equipment for specific chemical hazards discussed in the**  **following sections depends on the situations at the work site. Decis ions on the appropriate**  **equipment to be worn should be made by the project manager or coordinator. The following information is DEECO's Chemical Hygiene Plan. Its intent**  **is to protect laboratory employees from health hazards associated with the use of hazardous**  **chemicals in our laboratory and to assure that our laboratory employees are not exposed to substances in exc**  **ess of the permissible exposure limits as defined by OSHA in 29 CFR 1910 subpart Z.**  **The plan is available to all employees fro review and a copy will be located in the Health and Safety**  **files. The plan will be reviewed annually by the Health and Sa fety Officer and/or the directors of**  **DEECO. The following sections of this document and throughout the manual are sta**  **ndard operating procedures for which each DEECO employee has received adequate tr**  **aining and direction. If questions exist for the following information, it may be found throughout**  **this manual or in our memo file. It is the responsibility of each employee to be**  **aware of DEECO's standard operating procedures for the following:**  **Accidents, spills, avoidance of routine exposure, choice of chemicals , eating-drinking-smoking,**  **equipment and glassware, horseplay, mouth suction, personal apparel, house keeping, personal**  **protection, planning, unattended operations, use of the hood, waste disposal a nd storage, working**  **alone, corrosives, fires, explosions, low temperature, pressurized and vacuum operations,**  **compressed gasses, chemical storage. The following operations shall be performed in the LABORATORY FUME HOO**  **D: - Use of solvents unless in outdoor work areas**  **- Use of open flames or burning devices - Use of any organic or inorganic chemical or compound that is unstable**  **These include preparation of standards, transfer of solvents, disposal or consolidat ion of waste** **DEECO Health and Safety Plan Page 44 January 2010**

**Respirators shall be used in accordance with DEECO's respira tory protection policy and with the**  **OSHA respirator standard 29 CFR 1910.134. This policy and associated docum entation is filed in**  **the office of the Health and Safety Officer and/or safety files. Appropriate protective apparel compatible with the required de**  **gree of protection for substances handled shall be used. The Health and Safety Officer is availab**  **le to advise employees on glove, gown, eye protection, barrier creams, etc, use. Permeability**  **Charts are available in any safety catalog such as Lab Safety Supply, or SAFECO. Use of tradenames or r**  **eferences does not indicate a recommendation or approval of listed products or Companies.**  **All eyewash stations are clearly marked and identified by the use of green placards and red arrows**  **leading to the eyewash areas. Employees who need to use the eyewashes are ins tructed as to their**  **use and must irrigate for a minimum of 15 minutes and seek medical assistance immediately.**  **Eyewashes will be inspected by the safety officer every month. Employees have been issued a memorandum as to the procedures to foll**  **ow for fires and explosions. Exit routes are marked in each employee area.**  **Fume hoods will be inspected every six months by the Health and Sa fety Officer. Adequacy of face**  **velocity will be determined by the use of a propeller anemome ter and must reach a minimum of 200**  **fpm. An employee may request a hood inspection at any time should t hey suspect a problem with**  **the hood or ventilation system. No employee will work with any hazardous chemicals unless they have**  **been instructed by their project manager or health and safety officer. These chemic**  **als include; carcinogens, explosives, neurotoxins, reproductive damaging chemicals, or acutely hazardous chemicals.**  **DEECO shall provide, to affected employees, medical attention inc luding follow-up examinations**  **which MEDFIRST or another approved medical office determines is ne cessary under the following**  **circumstances. a. whenever an employee develops signs and/or symptoms associate**  **d with a hazardous chemical to which they may have been exposed, the employee shall**  **be provided an opportunity to receive appropriate medical examination. The emp**  **loyee shall contact the Health and Safety Officer to initiate the medical program.**  **b. Where exposure monitoring reveals an exposure level routinely ab ove the OSHA action level**  **(AL) (or in the absence of an action level, exposure above the OSH A permissible exposure**  **level (PEL)) for OSHA regulated substances for which there a re medical monitoring**  **requirements, medical surveillance shall be established for tha t employee. Listed OSHA**  **standard medical surveillance requirements include the chemical be nzene, formaldehyde,**  **methylene chloride. c. Whenever an event takes place in the laboratory or work area suc**  **h as a spill, leak, explosion, or other occurrence resulting in the likelihood of a hazardous exposure,**  **the affected employee, laboratory or custodial, shall be provided an opportunity for**  **a medical consultation. This consultation is for the purpose of determining**  **the need for a medical examination.** **DEECO Health and Safety Plan Page 45 January 2010**

**All aspects of these examinations are provided by a licensed p hysician, or supervised by a licensed**  **physician. These examinations are provided without cost to the empl oyee, without loss of pay, and**  **at a reasonable time and place. The Health and Safety Officer who is also the Chemical Hygie**  **ne Officer will provide information to the physician:**  **1. Identity of the hazardous chemical to which the employee may have been exposed. 2. A description of the conditions of the exposure including exposure date if available**  **3. A description of the signs and symptoms of exposure that the employee is experiencing (if**  **any). The physician's written opinion shall include:**  **1. Recommendations for future medical follow-up 2. Results of examination and associated tests**  **3. Any medical condition revealed that may place the employee at inc reased risk as the result**  **of a chemical exposure. 4. A statement that the employee has been informed by the physic**  **ian of the results and told of any medical conditions that may require additional examination of treatment.** 

3.1 General Characteristics Routes of Entry **There are three major routes through which chemicals can enter the body and potentially cause harm.** 

Inhalation: **Contaminants in the air can be absorbed into the bloodstream dire ctly through the**  **lungs. In this manner, the contaminant can be carried to any organ in the body.** Ingestion: **Ingestion of chemicals may severely damage the tissues of the digestive tr act, damage**  **the stomach or other organs. The chemical can be absorbed into the bloodstream, or other body**  **fluids, and carried to other organs in the body.** Skin Absorption: **The skin can act as a protective barrier to many chemical agents. However, many**  **chemicals can penetrate the skin. In this manner, the chemicals can enter the bloodstream and be**  **distributed throughout the body. Wounds on the skin (e.g. cuts and abrasions) offer a di rect route**  **for chemicals to enter the bloodstream.** Physical Characteristics of Chemicals **Below are definitions of terms used in the following Chemical Sa fety Sections. Additional**  **definitions are located in the Guide to Common MSDS Terms, located in Appendix C. Gas - a formless fluid which takes the shape of its container.**  **Vapor - the gaseous form of a substance which is normally a solid or liquid a t room** 

**temperature. Fog - a visible, liquid aerosol.**  **Mist - a "fog" where the liquid particles are large enough to be individually s een.**  **Fume - particle formed by the condensation of vaporized solids. DEECO Health and Safety Plan Page 46 January 2010** 

**Dust - solid particles, capable of temporary suspension in air. Smoke - airborne particles generated from incomplete combustion process**  **es. Carcinogen - a substance capable of causing cancer in animals or humans.**  **Mutagen - a substance capable of changing the genetic material in a livi ng cell.**  **Fetotoxin - a substance capable of causing death or injury to fetus. Teratogen - a substance which can cause deformations in a fe**  **tus from exposure of a**

**pregnant female.**

Health Hazards **Substances to which field employees may be exposed have the potential to cause severe injury or**  **illnesses. The degree of injury or illness is a function of the exposure; that is the amount of the**  **substance and the time that an employee is in contact with it. Below are descriptions of various types**  **of health hazards that may exist when working with hazardous substances.**

Irritant: **Several chemicals may be an irritant to the skin, eyes, or respir atory tract. Irritation can**  **range from mild discomfort to severe and irreversible chemical burns on the skin or eyes. Examples**  **of irritants include ammonia, acids, bases, and several solvents.**

Sensitizer: **A chemical that is a sensitizer may not elicit a res ponse after one exposure. After**  **repeated exposures, however, a severe reaction may occur, not necess arily at the point of contact.**  **The reaction may be a skin rash, or in the case of toluene diisocya nate, failure of the respiratory**  **system, Examples of sensitizers are formaldehyde, poison ivy, potassium di chromate.** 

Narcotic: **Narcotics cause a depression of the central nervous system, pr oducing a sleepy or dizzy**  **effect. Narcotics may make an employee unable to perform his /her work. Other safety hazards arise**  **when employees affected by a narcotic attempt to continue to work. Most organic solvents can**  **produce narcotic effects.** Asphyxiant: **An asphyxiant reduces the amount of oxygen available for use by the body. This can**  **cause suffocation, leading to coma or even death. There are two typ es of asphyxiants. A Simple**  **Asphyxiant reduces the amount of oxygen in an area. Examples of simple asphyxiants include**  **carbon dioxide, nitrogen, argon, and other inert gases. A second type of asphyxiant is called a**  **Chemical Asphyxiant. A chemical asphyxiant enters the body thr ough the lungs, and competes with**  **oxygen for space in the red blood cells. With these asphyxiants, suffocation can occur even if there**  **is plenty of oxygen in the room. Examples of chemical asphyxia nts include carbon monoxide, and**  **cyanide gas.** Systemic Poison of Toxin: **A systemic poison or toxin is a substance that produces an af fect away**  **from the point of contact. For instance carbon tetrachloride can be inhaled or absorbed through the**  **skin, but exhibits its major effects upon the liver and kidneys. It is important to remember that different chemicals react**  **differently with the body. Several chemicals exhibit more than one effect. The employee must re**  **view the MSDS for the specific chemical he/she is working with to fully understand all of the potential hazards.** **DEECO Health and Safety Plan Page 47 January 2010**

3.2 Acids
Potential Hazards Routes of Entry - Inhalation, Ingestion, Contact **1. Acids are corrosive substances having a pH < 7.0. 2. Acid vapors and fumes can cause irritation of the eyes, skin, and respiratory trac**  **t. 3. Chemical burns on tissue can occur if acids are allowed to contact skin, eyes, or lung**  **s. 4. Severe gastrointestinal pain and tissue injury can occur if acids are inge**  **sted.** Symptoms of Overexposure **Hazards of exposure are mainly from acute (short duration) exposur es. Effects of acid fumes**  **or vapors include eye, throat, nose, or lung irritation. Skin or eye cont act with acids may**  **result in severe chemical burns.**

First Aid **In the event that acid comes in contact with your skin or eyes:** # **Proceed immediately to the nearest eyewash station. Call for assistance from a co**  **worker if necessary.** # **Flush the affected area with copious amounts of water for at least 15 minutes. If**  **contact was with eye, pull the eyelid up and out, exposing the corne a, while flushing**  **with water.** # **Notify the project manager or coordinator and seek medical attention. If acid is spilled on your clothing:**  # **Remove contaminated clothing immediately.** # **Flush skin area with water for 15 minutes.** # **Notify the manager or coordinator and seek medical attention. Personal Protective Equipment**  **1. Gloves (Disposable Latex or Nitrile) 2. Protective Clothing (Saranex Tyvek Suits)**  **3. Respiratory Protection - Minimum or a half-mask, air-purifying respirator with Acid Gas or**  **Organic Vapor/Acid Gas Cartridges. 4. Eyewear - Minimum of safety glasses with side shields.**  **Recommend chemical splash goggles.** 

3.3 Bases
Potential Hazards Routes of Entry - Inhalation, Ingestion, Contact **1. Bases are corrosive substances having a pH > 7.0. 2. Vapors and fumes generated from bases can cause irritation of**  **the eyes, skin, and respiratory tract.** **DEECO Health and Safety Plan Page 48 January 2010**

**3. Chemical burns can occur if bases are allowed to contact skin or eyes. Bases can cause**  **irreversible damage to the eyes, even in dilute concentrations. 4. Severe gastrointestinal pain and tissue injury can occur if bases are i**  **ngested.** Symptoms of Overexposure **Hazards of exposure are mainly from acute (short duration ) expo sures. Effects of alkali**  **fumes or vapors include eye, throat, nose, or long irritation. Skin or ey e contact with bases**  **may result in severe chemical burns.**

First Aid **In the event that a base comes in contact with your skin or eyes:** # **Proceed immediately to the nearest eyewash station. Call for assistance from a co**  **worker if necessary.** # **Flush the affected area with copious amounts of water for a t least 15 minutes. If**  **contact was with eye, pull the eyelid up and out, exposing the cornea.** # **Notify the project manager or coordinator and seek medical attention. If a base is spilled on your clothing:**  # **Remove contaminated clothing immediately.** # **Flush skin area with water for 15 minutes.** # **Notify the project manager or coordinator and seek medical attention.** Personal Protective Equipment **1. Gloves (Disposable Latex or Nitrile) 2. Protective Clothing (Saranex Tyvek Suits)**  **3. Respiratory Protection - Minimum or a half-mask, air-purifying respirator with Acid Gas or**  **Organic Vapor/Acid Gas Cartridges. 4. Eyewear - Minimum of safety glasses with side shields. Rec**  **ommend chemical splash goggles.**  3.4 Compressed Gases
Potential Hazards Routes of Entry - Inhalation, Contact **1. Cylinders may explode if heated above 135** E **F or dropped, damaging the valve stem. 2. Fire Hazards may exist if a Flammable Gas, Oxygen or ot**  **her oxidizing gas cylinder is placed near an open flame.**  **3 Skin and eye burns may result if direct contact with an escaping gas is made. 4. Suffocation can occur if the concentration of a gas is allowed**  **to decrease the percent of oxygen in an area.**  **5. If Oxygen is allowed to be released, it may be absorbed int o clothing and take as long as 15**  **minutes to disperse. This could lead to a flash clothing fire if the person comes in contact**  **with an ignition source. 6. Severe burns may result from skin or eye contact with cryogenic gases.** **DEECO Health and Safety Plan Page 49 January 2010**

**7. Prolonged breathing of oxygen can be toxic. 8. A fire or explosion hazard may exist when using nitrogen and helium**  **, since these gases can condense oxygen from the air, creating an oxygen-rich environment at t**  **he location of the gas.** Symptoms of Overexposure **Symptoms of overexposure to compressed gases depends on the specific gas. Ref er to the**  **MSDS of the gas for this information.** General Handling Procedures **1. Cylinders should be tagged with a FULL, IN USE, or EMPTY Status Tag at all t imes.**  **2. Cylinders must have the valve protection cap in place when being moved. 3. Cylinders shall be stored such that they are protected from ex**  **cessive heat or open flame (125**

E **F), physical shock, and electrical circuits. 4. Cylinders shall be secured using a chain or strap, to a wall, bench or other firm**  **support. 5. Never completely empty a gas cylinder.**  **6. Never use oil on regulator valves or connections. Oil can degrade the regulator diaphragm,**  **contaminate the gas, or be oxidized in air to form explosive products. 7. Use only CGA (Compressed Gas Association) approved regulators**  **and fittings for the specific gas being used. Do not mix a given regulator with different gases.**  **8. Do not tamper with manufacturer's safety devices or check valves. 9. Leak-test all fittings and connections using an appropriate leak-test solut**  **ion. 10. Jewelry should not be worn when handling or using cryogens.**  **11. If a cylinder should develop a leak:** # **Remove all sources of spark or flame.** # **Place in exhausted enclosure or remove to a safe outdoor area.** # **Identify the cylinder as "Leaking Cylinder". Notify the supplier.** # **For Flammable Gases, attach a control valve to the cylinder valve and allow the gas**  **to escape. Adjust to a moderate discharge rate. 12. If a cylinder containing cryogenic gases is dropped:**  # **Evacuate area within 100-ft radius of cylinder;** # **Keeping a safe distance (no less than 50 feet), determine if the cylinder's inner vessel**  **relief valve is venting, or if the outer vessel bursting disc ha s ruptured. If either is**  **venting gas, do not approach until there is no further discharge.** # **When emission from the cylinder has not been noticed for 15 minutes, car efully open**  **the vent valve and the gas withdrawal valve to empty the cylinder. Move away from**  **the cylinder after opening valves.** # **Once emptied, place in upright position. Write "Dropped Cylinde r" on the cylinder**  **status tag and notify the supplier.**

First Aid **If skin or eye contact occurs, flush area with unheated water and apply cold compresse s.** **DEECO Health and Safety Plan Page 50 January 2010**

Personal Protective Equipment **Safety glasses should be worn at a minimum. Cryogenic gloves shoul d be worn if contact with a**  **cryogenic gas is possible.** 3.5 Cryogenic Materials **Cryogenic materials are substances that are kept at very low tempera tures (less than 100**  E **F). Cryogenics may be liquids or solids. Atmospheric gases, such as**  **nitrogen, oxygen, or hydrogen, that are cooled to temperatures less than 150**  E **F become liquified and are examples of cryogenic materials. "Dry Ice" is another example of a super-cooled gas, carbon dioxi**  **de.**

Potential Hazards Routes of Entry - Contact, Inhalation **1. Severe burns may result from skin or eye contact with cryogenic materials**

**. 2. Some liquid gases can deplete the available oxygen in a room S**  **uffocation can result if not used in a well-ventilated area.**  **3. Prolonged breathing of pure oxygen may have harmful physiological effects**

**. 4. Nitrogen and helium can condense oxygen from the air, creating an oxy**  **gen-rich environment at the location of the gas. This could be a fire or explosion hazard.**  **5. Cryogenic gases are stored under high pressure. This creates the same potential hazards as**  **other compressed gases (see Section 3.4). 6. Hydrogen is extremely flammable and is a fire and explosion hazard.**  **7. Liquid oxygen, while not flammable itself, does increase the fla mmability of ordinary**  **combustibles.** General Handling Procedures **1. When there is the potential for contact with a cryogenic mate rial, a full face shield will be**  **required. In addition, a lab coat and gloves suitable for cold materi al handling shall be worn.**  **2. Jewelry should not be worn when handling or using cryogens. 3. When handling cryogens, trousers should not have cuff.**  **4. Use tongs to remove objects that are immersed in cryogenic li quids. Never use your hands,**  **even if wearing gloves!! 5. Use only in well-ventilated areas.**  **6. Store away from flammable and combustible materials. 7. Do not use near open flame or spark-producing equipment.**  Emergency Procedures **1. If skin or eye contact occurs, flush area with unheated water and a pply cold compresses.**  **Notify your supervisor and seek medical attention. 2. If a cylinder containing cryogenic gases is dropped:**  # **Evacuate area within 100-ft radius of cylinder; DEECO Health and Safety Plan Page 51 January 2010** 

# **Keeping a safe distance (no less than 50 feet), determine if the cylinder's inner vessel**  **relief valve is venting, or if the outer vessel bursting disc has ruptured. If either is**  **venting gas, do not approach until there is no further discharge.** # **When emission from the cylinder has not been noticed for 15 minutes, car efully open**  **the vent valve and the gust withdrawal valve to empty the cylinder. Move away from**  **the cylinder after opening valves.** # **Once emptied, place in upright position. Write "Dropped Cylinde r" on the cylinder**  **status tag and notify the supplier.** 3.6 Flammable Liquids and Gases
Potential Hazards Routes of Entry - Inhalation, Ingestion, Contact **1. Flammable liquids and gases pose significant fire and explosion hazards. 2. Many flammable liquids:**  # **Can be readily absorbed through the skin.** # **Can cause dermatitis.** # **Are systemic poisons once in the body. 3. Eye, skin and respiratory tract irritation may occur.**  **4. Many flammable liquids and gases can produce depression of the c entral nervous system**  **(decreases motor response, dizziness, etc.)** Systems of Overexposure **Symptoms of overexposure to flammable liquids and gases will de pend on the specific**  **substance. Refer to the MSDS of the chemical for this information.**

General Procedures **1. Keep flammable materials away from open flame, sparks, or excessi ve heat.**  **2. Keep away from oxidizing agents such as oxygen. 3. Store in chemical cabinet, isolated from other chemicals.**  **4. Keep combustible material such as wood, cloth, and paper out of storage cabinet s.**  **5. Do not leave containers of flammable materials in work areas overnight. Return all bottles**  **to the proper storage cabinet. 6. Flammable liquids and gases should be used only in well ventilated areas.** 

First Aid **1. If skin or eye contact occurs, flush affected area with water for 15 minutes. Remove**  **contaminated clothing. Seek medical attention. 2. In the event of a burn; extinguish flames by applying a fire blanket, or roll**  **ing on the floor. Do not attempt to fan out the flames.**  **3. Use only an approved fire extinguisher to extinguish flames. Do not use water on flammable**  **liquid fires. Pouring water on these fires may only spread the flames over a wider area.** **DEECO Health and Safety Plan Page 52 January 2010**

Personal Protective Equipment **1. Gloves (Disposable Latex or Nitrile) 2. Eyewear - minimum of safety glasses with side shields. Che**  **mical goggles required if there is a potential for splash.**  3.7 Organic Solvents
Potential Hazards Routes of Entry - Inhalation, Ingestion, Contact **1. Solvents can cause skin, eye and respiratory tract irritation. 2. Solvents may cause defatting of the skin, which lessens the abi**  **lity of the skin to protect against other chemicals.**  **3. Some solvents are also systemic toxins and can produce effects on the liver, kidneys, and**  **other organs if allowed to be absorbed through the skin. 4. Inhalation of solvent vapors may produce narcotic or anesthetic effe**  **cts, and depression of the central nervous system.**  **5. Many organic solvents are also flammable.** Symptoms of Overexposure **Symptoms of overexposure to solvents will depend on the specific su bstance. Refer to the**  **MSDS of the chemical for this information.**

General Procedures **1. Use solvents only in local exhaust hood or well ventilated areas. 2. Do not continue to work if you feel dizzy or sleepy. Have a co-worke**  **r secure your apparatus (turn off heat, close containers, etc.) and escort you away from the area.** 

First Aid **1. If skin or eye contact occurs, flush affected area with water for 15 minutes. Remove affected**  **clothing. 2. If dizziness occurs from inhalation, get to fresh air.**  **3. In the event of a spill:** # **Turn off all sources of flame or sparks. Keep area well ventilated.** # **Small spills can be handled by using a solvent spill kit. 4. Use only an approved fire extinguisher to extinguish flames. D**  **o not use water on liquid fires. Pouring water on these fires may only spread the flames over a wider are**  **a.** Personal Protective Equipment **1. Gloves (Disposable Latex or Nitrile) 2. Eyewear - minimum of safety glasses with side shields. Che**  **mical goggles required if there is a potential for splash.** **DEECO Health and Safety Plan Page 53 January 2010**

3.8 Oxidizing Agents
Potential Hazards Routes of Entry - Inhalation, Ingestion, Contact **1. Oxidizing agents can be irritating to skin, eyes, and the respiratory trac t.**  **2. Most oxidizing agents are highly reactive, and may react violentl y with metals, as well as**  **other chemicals. 3. Oxidizers are corrosive and can cause burns on skin and eyes.**  **4. Oxidizers spontaneously evolve oxygen, and therefore may create a fire on explosion hazard**  **in some environments.** Symptoms of Overexposure **Symptoms of overexposure to solvents will depend on the specific sub stance. Refer to the**  **MSDS of the chemical for this information.**

General Procedures **1. Do not mix with organic solvents. 2. Always store in unbreakable, inert containers.**  **3. Do not use cork or rubber stoppers. 4. Respiratory protection is required when handling chlorine or bromine gas.**  **5. Label containers of oxidizers with the date received, and the date the container was first**  **opened.**

First Aid **1. If skin or eye contact occurs, flush affected area with water for 15 minutes. Remove affected**  **clothing. 2. In the event of a spill:**  # **Turn off all spark and open flame sources.** # **Cover spill area with a bisulfite solution. Mix well and spra y with water. Place**  **waste in container with water. 3. If a gas leak occurs, remove all sources of spark or flame.**  **Place cylinder in an exhausted enclosure or remove it to a safe outdoor area as soon as possible.**  Personal Protective Equipment **1. Gloves (Disposable Latex or Nitrile) 2. Eyewear - minimum of safety glasses with side shields. Che**  **mical goggles required if there is a potential for splash.** 

3.9 Asbestos Awareness **Asbestos is the name applied to six naturally occurring minera ls that are mined from the earth.**  **Because it is so hard to destroy asbestos fibers, the body cannot break the m down or remove them**  **once they are lodged in lung or body tissues. They remain in place where they can caus e disease.**  **There are three primary diseases associated with asbestos exposure: Asbestosis**  **Lung Cancer Mesothelioma** **DEECO Health and Safety Plan Page 54 January 2010**

**DEECO personnel may be exposed to asbestos while on a client's premises. The most common use**  **of asbestos at our client’s facilities is insulation on pipe s and vessels. Asbestos boiler insulation**  **does not present a hazard unless the protective covering is c ut or damaged in such a way that the**  **asbestos underneath is actually exposed to the air. The project manager/field team leader will ensure**  **that the client has identified or provided means to identify asbestos-containing e quipment.**  **If you do not know whether something is asbestos or not, assume that i t is until it is verified**  **otherwise.**

**DO NOT DISTURB IT. Never...**  **Drill Hammer**  **Cut Saw**  **Break Damage**  **Move Disturb**  **...any asbestos-containing materials or suspected materials.**

3.10 Benzene Awareness **Benzene is a volatile chemical formed from both natural processe s and human activities. Natural**  **sources of benzene include emissions from volcanoes and forest fires. Benzene is also a natural part**  **of crude oil, gasoline, and cigarette smoke. Benzene is widely used i n the United States, ranking in**  **the top 20 chemicals for production volume. It is primarily used as a solvent, as a starting material**  **for the production of other chemicals, and as a gasoline additive. Brea thing benzene can cause**  **drowsiness, dizziness, and unconsciousness; long-term benzene exposure ca uses effects on the bone**  **marrow and can cause anemia and leukemia. The Occupational Safety and Health Administration**  **(OSHA) recognizes benzene as a hazardous material and imposes strict exposure limits in the**  **workplace. It is unlikely that DEECO personnel would be exposed to benzene on a**  **client's premises at levels above the OSHA permissible exposure limits (1 ppm TWA for 8**  **hour and 5 ppm STEL for 15 minutes). If the potential for benzene exposure exists, the proje**  **ct manager/field team leader will ensure that the client has identified regulated areas where the**  **permissible exposure limits could be exceeded.**  **DEECO does not use benzene for any sample recovery procedures.** 3.11 Hydrogen Sulfide Awareness **Hydrogen sulfide (H 2**  **S) is a colorless gas with a powerful nauseating smell of rot ten eggs. The odor**  **is a poor warning property because hydrogen sulfide exposure quickly dea dens the sense of smell.**  **The gas is heavier than air and may collect in low areas such a s sewers, pits, tunnels or gullies. High**  **airborne levels of hydrogen sulfide (between 4.3 and 46.0 percent of gas by volume in the air) may**  **catch fire if there is a source of ignition. If the gas is burned, toxic p roducts such as sulfur dioxide** **DEECO Health and Safety Plan Page 55 January 2010**

**will be formed. Hydrogen sulfide is incompatible with oxidizing a gents, such as nitric acid and**  **chlorine trifluoride, and may react violently or ignite spontaneously. Hydrogen sulfide is extremely toxic. It may cause death instant**  **aneously in high airborne concentrations. Low levels may be extremely irritating to the lungs, nose, throa**  **t and eyes. Hydrogen sulfide can be detected by smell at levels as low as**  **0.13 parts hydrogen sulfide per million parts air (ppm). Odor cannot be used as a warning because the ga**  **s can deaden the sense of smell within 2 to 15 minutes in exposures of approximately 100 ppm. A single**  **breath of hydrogen sulfide at about 1000 ppm may paralyze the respiratory system and resul**  **t in coma and death. Convulsions may also occur. Prolonged exposure at about 250 ppm hydrogen sulfide may cause t**  **he lung tissue to swell and fill up with water (pulmonary edema).**  **This effect may occur after the exposed worker recovers from t he irritant effects of the gas.**  **Exposures of 20 to 50 ppm hydrogen sulfide for one hour may cause inflamma tion of the cornea and**  **the delicate lining of the eye and eyelid (a condition called kerat oconjunctivitis). Exposures for long**  **periods at 50 ppm may cause severe irritation of the nose, throat and lungs. Workers exposed to**  **lower concentrations of hydrogen sulfide may develop headaches, eye disorders and chronic**  **bronchitis. DEECO personal may be exposed to hydrogen en sulfide on a client's**  **premises at levels above the OSHA permissible exposure limits (20 ppm (ceiling) with the**  **following exception: if no other measurable exposure occurs during the 8-hour work shift, exposures may**  **exceed 20 ppm, but not more than 50 ppm (peak), for a single time period up to 10 minutes.).**  **Small amounts of hydrogen sulfide occur in crude petroleum but natural gas can contain up to 90%**  **. By far the largest industrial route to H**  **2 S occurs in petroleum refineries. Other sources of hydrogen sulfide**  **include coke ovens, paper mills (using the sulfate method), and tanneries. H**  **2 S arises from virtually anywhere where**  **elemental sulfur comes into contact with organic material, especially at high temperatures.**  **Should the potential exist for exposure to H 2**  **S, the project manager/field team leader will work with the client to ensure that all personnel are provided with the following training;**  **1. Identification of the characteristics, sources, and hazards of Hydrogen Sulfide, 2. Proper use of the Hydrogen Sulfide detection methods used on the site,**  **3. Recognition of, and proper response to, Hydrogen Sulfide warnings at the workplac e,**  **4. Symptoms of Hydrogen Sulfide exposure, 5. Proper rescue techniques and first-aid procedures to be used in a**  **Hydrogen Sulfide exposure, 6. Proper use and maintenance of personal protective equipment. Demons**  **trated proficiency in using PPE should be required,**  **7. Worker awareness and understanding of workplace practices and mai ntenance procedures**  **to protect personnel from exposure to hydrogen sulfide, 8. Wind direction awareness and routes of egress,**  **9. Confined space and enclosed facility entry procedures. 10. Locations and use of safety equipment,**  **11. Locations of safe briefing areas, 12. Use and operation of all Hydrogen Sulfide monitoring systems, and**  **13. Emergency response procedures, corrective action, and shutdown procedures. DEECO Health and Safety Plan Page 56 January 2010** 

**At most client facilities where hydrogen sulfide exposure coul d occur, this training is required by**  **the client prior to entry.**

3.12 Lead Awareness **Lead is a toxic metal that was used for many years in products found in and around our homes. Lead**  **also can be emitted into the air from motor vehicles and industria l sources, and lead can enter**  **drinking water from plumbing materials. Lead may cause a range of health effects, from behavioral**  **problems and learning disabilities, to seizures and death. Childre n six years old and under are most**  **at risk. Most Common Sources of Lead Poisoning:**  **1. Deteriorating lead-based paint, 2. Lead contaminated dust, and**  **3. Lead contaminated residential soil DEECO personal may be exposed to lead hazards created by renova**  **tion, repair and painting (RRP) activities at client facilities that disturb lead-based pa**  **int. The lead exposure limit is fifty micrograms per cubic meter of air (50 ug/m**  **3 ) averaged over an 8-hour period. The project manager/field team**  **leader will ensure that the client has identified any areas wh ere the potential for exposure to lead**  **exists and access these areas by DEECO employees will be prohibi ted.** **DEECO Health and Safety Plan Page 57 January 2010**



### 4.0 Hazard Communication Requirements

Introduction **The Occupational Safety and Health Administration's (OSHA) Ha zard Communication Regulation**  **(29 CFR 1910.1200) requires that employees be informed of all hazardous che micals located in their**  **workplace. This program will describe how DEECO intends to protect the safe**  **ty and health of our employees who are exposed to hazardous chemicals in the workplace, and to compl**  **y with the provisions of 29 CFR 1910.1200.**  **Each supervisor will be held responsible for strict adherence to these policies and will closely**  **monitor all activities involving hazardous chemicals. Each employee will carefully follow established work practic**  **es and promptly report observed or potential problems to supervision.**  **There is no job at DEECO so vital or urgent as to justify the risk of employee overexposure to a**  **hazardous chemical. Ask when in doubt. Proceed with a job only afte r being satisfied that it is safe**  **for you to do so. A list of all hazardous chemicals for each workplace has been made and is re**  **adily available, upon request, to any employee, working on any shift. It is located in eac**  **h tow vehicle, shop area, and wet chemistry lab.**  **DEECO is responsible to ensure that the list of hazardous chemic als is kept current and that a current**  **MSDS for each hazardous chemical used is on hand. A chemical that is not shown on the curre nt**  **list will not be ordered without prior coordination with the wet chemistry lab m anager.**  **All containers of hazardous chemicals in each workplace will be conspicuously labeled with the**  **identity of the chemical, and the appropriate hazard warnings. I f the chemical is a known or**  **suspected carcinogen, or it is known to affect a specific organ of the body, this information will also**  **be placed on the container label. The person having supervisory re sponsibility for the storage or use**  **or each hazardous chemical will ensure that such labels are not de faced and that they remain legible**  **at all times. The health and safety officer will ensure that an adequate supply of labels are on hand**  **and made available to the responsible supervisors. When an outside contractor is used, it will be the responsibility**  **of the project manager to advise the contractor of any hazardous chemical to which their employees may**  **be exposed and the appropriate protective measures to be taken. This procedure also works conversely.**  **All employees exposed to any hazardous chemicals will complet e an information and training**  **program which includes at least the subjects listed below. New employee s must complete similar**  **instructions before initial exposure to any hazardous chemical in the workplac e.** **DEECO Health and Safety Plan Page 58 January 2010**

**Adequate training of all employees exposed to hazardous chemicals will be given by the Health and**  **Safety Officer or an approved training instructor and assisted as needed by the Hazard**  **Communication Program Monitor. Employee information for this program will include:**  **1. The purpose and need for such a program, including the basic concept that gives every employee**  **the right to know about hazardous chemicals with which they work. 2. The location and availability of the written Hazard Communicati**  **on Program, plus the list of hazardous chemicals and their corresponding MSDS's.**  **3. The identity upon request, of any chemical to which the emp loyee id exposed. In the case of a**  **trade secret chemical, the name on the MSDS will be provided. Employee training shall include at least the following:**  **1. Methods and observations used to detect the presence or release of a hazardous chemical in the**  **work ares such as monitoring devices, appearance, or odor. 2. The physical and health hazards associated with each chemical, as specifie**  **d in the MSDS. 3. Action that employees can take to protect their own safety and**  **health, including specific procedures that have been established for normal work practices, e**  **mergency procedures, and policies on the use of personal protective equipment.**  **4. Details of the Hazard Communication Program, including an explanat ion of the labeling system**  **used on in-house containers of hazardous chemicals. Also, details of how e mployees can obtain and**  **use information contained in the MSDS. It is the intent of DEECO management to protect the safety a**  **nd health of each employee, our most valuable and valued asset. By following correct procedures, no employ**  **ee should experience and harmful effects from working with chemicals in their workplace.**  Client Responsibilities **Clients are required to inform DEECO personnel working on the premi ses of all hazards located in**  **the area. In addition to chemical hazards, the client should inform DEECO:** # **Location of all emergency exits.** # **Location of nearest medical facilities.** # **Location of nearest emergency equipment (fire extinguishers, sa fety showers,**  **eyewashes, etc.) The client should have available for DEECO personnel MSDSs on al**  **l chemicals located in the area(s) where DEECO will be performing work.**  **The team leader should ensure that the above information is obtained before s etting up equipment**  **to perform the work. DEECO Health and Safety Plan Page 59 January 2010** 

DEECO Responsibilities **DEECO is required to inform its employees of all hazards that they may contact. MSDSs for each**  **chemical used by the Field Division are available in the centra l MSDS file located at the field office.**  **DEECO must also supply the client, upon request, information on the chemicals which DEECO**  **brings on the client's premises to perform field work. MSDS s are present prior to entering the**  **client's premises.** Written Program **The OSHA regulation requires that DEECO have a written Hazard Communication Program. The**  **written program for the Field Division is located in Appendix D of this Health and S afety Plan.**  4.1 Material Safety Data Sheets **The manufactured or distributor of chemicals used by DEECO is required to supply DEECO with**  **a MSDS. Employees must be informed of the information on the MSDS prior to working with a**  **chemical. A MSDS must exist for all hazardous chemicals. MSDSs for che**  **micals used on a client's site must be available for review or photocopying by the client. A lis**  **t of all chemicals brought on site by DEECO should be supplied to the client. The client should be informed that a MSDS**  **is available for each chemical on that list.**  **Hazardous materials that require a MSDS are substances whic h may present a physical or health**  **hazard. A material presents a** Physical Hazard **if it is:** # **Flammable** # **Combustible** # **Explosive** # **Reactive** # **Under Pressure A material presents a**  Health Hazard **if it is:** # **Corrosive** # **An Irritant** # **A Sensitizer** # **A Carcinogen** # **Harmful to body organs, including skin, eyes, reproductive organs, liver , kidneys,**  **lungs, blood, or nervous system. Each MSDS is required to provide the user with the following information:** 

Section I **- Supplier Information. This section must include the manufacturer 's name, address, and**  **an emergency telephone number. Also included in Section I is the nam e of the chemical as it appears**  **on the chemical label. Synonyms for the chemical name may also be given. DEECO Health and Safety Plan Page 60 January 2010** 

Section II **- Hazardous Ingredients Information. This section will list all the hazardous ingredients**  **of the chemical if they constitute 1% of the mixture or more. If the hazardous ingredient is a**  **carcinogen (capable of causing cancer), the ingredient will be listed if it constitutes 0.1% of the**  **mixture or more. Also listed for each ingredient will be the p ercentage that it makes up of the**  **mixture, and its current permissible exposure level (PEL).**

Section III **- Physical/Chemical Characteristics. This section will l ist characteristics such as boiling**  **point, vapor pressure, specific gravity, melting point, vapor densit y, evaporation rate, and solubility**  **in water. The substance's appearance and odor characteristics will also b e given.** 

Section IV **- Fire and Explosion Hazard Data. Included in this section will be the chemical's flash**  **point, flammability limits (upper and lower), the correct typ e of material to use to extinguish a fire,**  **any unusual fire and explosion hazards, and any special fire fighting procedures.**

Section V **- Reactivity Data. This section will list any conditions that should b e avoided with this**  **chemical, whether or not the chemical is stable, substances the chemical is incompatible with, any**  **hazardous decomposition products or any hazardous polymerization that may occur.**

Section VI **- Health Hazard Data. Information included in this section will be possible routes of**  **exposure, signs and symptoms of overexposure (both acute and chromic exposures), medical**  **conditions that may be aggravated by exposure to this chemical, and emergency first aid.** 

Section VII **- Precautions for Safe Handling. This section will list step s to be taken in the event of**  **a spill or release of the chemical, the proper waste dispos al methods, and any precautions that should**  **be taken during handling and storage.**

Section VIII **- Control Measures. Included in this section will be the proper personal protective**  **equipment (respiratory protection, gloves, eye/face protection), t he required ventilation system, and**  **other work practices that should be followed when using this chemical.**

Section IX - **Additional Information. This section will list any other pertinent information such as**  **transportation requirements or where to get other information regarding the chemi cal.**  4.2 Chemical Labelling **All chemicals used in the field or at DEECO must be labelle d. Chemical containers received from**  **the manufacturer are required to contain the chemical's name, hazar d warnings, and the**  **manufacture's name and address. This manufacturer's label may not be defaced in any manner.**  **Beakers and other containers used by DEECO employees must also b e clearly labelled with the**  **chemical name at all times. Several chemical manufacturers place the NFPA (National Fir**  **e Protection Association) hazard label on the bottle. This label identifies some of the hazardous properties of the che**  **mical. Transfer containers used by more than one employee must be label**  **led. Chemical formulas must not be used (for example, use "Acetone" instead of CH**  **3 COCH**  **3 ).** **DEECO Health and Safety Plan Page 61 January 2010**

4.3 Employee Exposure Monitoring **In order to ensure that field personnel are not overexposed to hazar dous materials, the DEECO**  **Safety Officer may direct the Project Manager or Coordinator to perform employee exposure**  **monitoring. Results from monitoring surveys will be forwarded to the departme**  **nt managers. The manager must review the report with each employee in the department. This c**  **an be accomplished by reviewing the report in a department meeting or circulating the report t**  **o all employees. Employees must sign an Employee Notification Form which accompanies the report. The**  **employees' signatures indicate that the report was reviewed and understood by each employee. The de**  **cision to monitor employee exposure will be made on a project-by-project basis by the DEE**  **CO S.O. and the Project Manager or Coordinator.**  **The department managers must retain copies of all monitori ng reports. These reports should be**  **reviewed with all new employees, or employees being reassigne d to the area, before allowing the**  **employee to work in the area. Employees may review past sampling reports that are repr**  **esentative of their exposure by contacting their department manager, the Director of Personnel, or the DEECO S.O.**  4.4 Employee Medical Surveillance **DEECO requires each employee to take a pre-employment physical. This physical establishes the**  **employee's physical condition before performing work at DEECO. In addition, DEECO field**  **employees will receive annual physicals based upon their job descrip tion and age.**  **Employees may receive additional medical evaluation if:** # **Signs or symptoms associated with exposure to a hazardous chemica l at DEECO**  **develop.** # **Routine exposure monitoring indicate that employee exposure exceeds the**  **Permissible Exposure Level or Action Level for a given substance.** # **A spill, leak or other event occurs which may have resulted in exp osure to a**  **hazardous exposure. These physicals will be provided during normal working hours (when poss**  **ible) and at no cost to employees. Copies of all medical evaluations will be forwar**  **ded to the Director of Personnel for placement in the employee's confidential, personal file. Physic**  **al evaluations made under the above conditions shall not reveal findings of diagnoses unrelated to the employ**  **ee's occupational exposure. Employees may at any time, review all medical information on f**  **ile by contacting either the department manager or the Director of Personnel.**  4.5 Employee Access to Records **Employees may be asked to participate in chemical exposure monitoring. DEECO will maintain**  **records of employee medical surveillance, exposure monitoring, and oc cupational accidents or**  **injuries. As per OSHA regulations, this information may be re viewed by employees by requesting** **DEECO Health and Safety Plan Page 62 January 2010**

**the information from the Area Supervisor, Manager or the Personnel Director. A copy of the OSHA**  **standard regarding access to exposure and medical records may be obtained from the DEECO S.O.**  **Responsibilities The DEECO Safety Officer must ensure that:**  # **All employee exposure monitoring reports are reviewed by emp loyees, and that**  **employees acknowledge the receipt of the reports by signing the report.** # **Copies of the signed report are sent to the Personnel Director.** # **Other information, such as MSDSs, ventilation records, etc. are mai ntained for at**  **least 30 years. The Personnel Director must ensure that:**  # **Employee medical, exposure and accident/injury records are maint ained for the**  **length of employment plus thirty (30) years.** # **A response to any internal and external requests for medical or exposure records is**  **given within 15 working days. The Department Managers must ensure that:**  # **Employees review and sign all Employee Exposure reports.** # **Employees are advised of the right to access medical and exposur e records annually**  **in a department safety meeting. DEECO Health and Safety Plan Page 63 January 2010** 



### 5.0 Personal Protective Equipment **The procedures and guidelines detailed in the following sections are to be used by DEECO Field**  **personnel while performing work on either DEECO or client premis es. If the client has additional**  **requirements for personal protective equipment, field personnel are to follow the procedures which**  **are more stringent. In all cases, all OSHA and/or EPA require ments are to be met. Field personnel**  **are not to use personal protective equipment for which they have not r eceived adequate training in**  **their use and limitations. Protective equipment, including personal protective equipment for eye**  **s, face, head, and extremities, protective clothing, respiratory devices, and protective shields and**  **barriers, will be provided, used, and maintained in a sanitary and reliable condition wherever it is**  **necessary by reason of hazards of processes or environment, chemical hazards, radiological hazards, or m**  **echanical irritants encountered in a manner capable of causing injury or impairment i**  **n the function of any part of the body through absorption, inhalation or physical contact.**  **Where employees provide their own protective equipment, DEECO wil l be responsible to assure its**  **adequacy, including proper maintenance, and sanitation of such equipment. All personal protective equipment shall be of safe design and c**  **onstruction for the work to be performed. The protective equipment, including personal protective**  **equipment (PPE) will be provided by DEECO at no cost to employees. DEECO will pay for**  **replacement PPE, except when the employee has lost or intentionally damaged the PPE.**  5.1 Respiratory Protection **Detailed information regarding the use of specific respirators is located in the DEECO Field Division**  **Written Protection Program.**

Use **Only employees that have been trained in the use of respiratory protection shall select or wear**  **respirators. Employees must:** # **Be fit-tested and trained annually.** # **Ensure that equipment is clean, available, and in good repair.** # **Use equipment only as instructed.** # **Receive medical clearance to wear a respirator.** # **Not have beards, long side-burns, or other conditions that may preclude a good face**  **to-facepiece seal.** # **Ensure that the proper respirator cartridge or canister i s used for a particular**  **contaminant. All cartridges are marked and color-coded. When donning the respirator:**  # **Place mask on face with chin in chin-cup.** # **Attach lower straps around neck.** # **Place top straps on crown of head, above ears.** # **Tighten all straps. DEECO Health and Safety Plan Page 64 January 2010** 

**Each time the respirator is conned, positive and negative pressure fit-chec ks must be performed.**  **Positive Pressure Fit-Checks:** # **Place the palm of hand over the exhalation valve.** # **Exhale gently. The mask should lift off the face without allowing the air to escape.**  **Negative Pressure Fit-Checks:** # **Cover the inlets of the cartridges with hands.** # **Inhale gently. The mask should collapse around the face without letti ng air in around**  **the face-to- respirator seal.**

Selection **Respirators provide specific Protection Factors based on the type to res pirator and the cartridge or**  **canister in use. The Protection Factor is defined as the concentra tion of an air contaminant outside**  **the mask divided by the concentration of that some contaminant inside the mask. For example, the**  **half-mask respirator with HEPA (High Efficiency Particula te Absolute) filter cartridge has a**  **Protection Factor of 10. This indicates that if worn in an area with a concentra tion of 0.05 mg/m**  **3 of airborne lead, the employee would actually be exposed to 0.005 mg/m**  **3 of lead.**  **Employees should select the type of respirator and cartridge ba sed on the decision criteria located**  **in the DEECO Respiratory Protection written program.** Inspection **Employees must inspect each respirator prior to donning. Straps , inhalation and exhalation valves,**  **cartridge gaskets, and facepiece should be inspected to ensure al l parts are present, clean and in good**  **condition.**

Decontamination **Respirator should be cleaned after each use. Remove cartridges and place the m in a plastic bag.**  **Wash respirator with warm, soapy water. Rinse the respirator thoroughly since soap can be a skin**  **irritant. Allow respirator to air dry. Place in plastic bag when dry and store in dry location away**  **from excessive heat. Do not place anything on top of respirator since this may distort the facepiece.**  Breathing Air Quality and Use **When DEECO employees are required to use atmosphere-supplying r espirators (supplied-air and**  **SCBA), DEECO will ensure that compressed air, compressed oxyg en, liquid air, and liquid oxygen**  **used for respiration accords with the following specifications: 1. Compressed and liquid oxygen shall meet the United States Pharma**  **copoeia requirements for medical or breathing oxygen;**  **2. Compressed breathing air shall meet at least the requireme nts for Grade D breathing air**  **described in ANSI/Compressed Gas Association Commodity Specificati on for Air, G-7.1-**  **1989, to include and oxygen content (v/v) of 19.5-23.5%, a hydrocarbon (condensed) content of 5 milligrams per cubic meter of air or less, a carbon m**  **onoxide (CO) content of 10 ppm or less; a carbon dioxide content of 1,000 ppm or less; and lack of noticeable odor.** **DEECO Health and Safety Plan Page 65 January 2010**

**DEECO will ensure that compressed oxygen is not used in atmosphe re-supplying respirators that**  **have previously used compressed air and ensure that oxygen concentrati ons greater than 23.5% are**  **used only in equipment designed for oxygen service or distribution. DEECO will ensure that cylinders used to supply breathing air**  **to respirators meet the following requirements:**  **1. Cylinders are tested and maintained as prescribed in the Ship ping Container Specification**  **Regulations of the Department of Transportation (49 CFR part 173 and part 178); 2. Cylinders of purchased breathing air have a certificate of ana**  **lysis from the supplier that the breathing air meets the requirements for Grade D breathing air; and**  **3. The moisture content in the cylinder does not exceed a dew point of - 50 deg.F (-45.6 deg.C)**  **at 1 atmosphere pressure. DEECO will ensure that compressors used to supply breathing ai**  **r to respirators are constructed and situated so as to:**  **1. Prevent entry of contaminated air into the air-supply system; 2. Minimize moisture content so that the dew point at 1 atmosphere**  **pressure is 10 degrees F (5.56 deg.C) below the ambient temperature;**  **3. Have suitable in-line air-purifying sorbent beds and filters to further ensure breathing air**  **quality. Sorbent beds and filters shall be maintained and replace d or refurbished periodically**  **following the manufacturer's instructions; 4. Have a tag containing the most recent change date and the signatur**  **e of the person authorized by the employer to perform the change. The tag shall be maintained at the comp**  **ressor. For compressors that are not oil-lubricated, the DEECO will e**  **nsure that carbon monoxide levels in the breathing air do not exceed 10 ppm.**  **For oil-lubricated compressors, the DEECO will use a high-tem perature or carbon monoxide alarm,**  **or both, to monitor carbon monoxide levels. If only high-temperature ala rms are used, the air supply**  **shall be monitored at intervals sufficient to prevent carbon monox ide in the breathing air from**  **exceeding 10 ppm. The DEECO will ensure that breathing air couplings are incomp**  **atible with outlets for non-respirable work site air or other gas systems. No asphyxiating substance**  **shall be introduced into breathing air lines.**  **DEECO will use breathing gas containers marked in accordance wi th the NIOSH respirator**  **certification standard, 42 CFR part 84. DEECO Health and Safety Plan Page 66 January 2010** 

5.2 Gloves
Use & Selection **Gloves should be worn when there is a potential for skin contact, suc h as pouring chemicals,**  **washing glassware with solvents, collecting samples, etc. Dif ferent gloves protect against different**  **chemicals. The glove compatibility chart below should be consulted when selec ting gloves.**  Inspection **Employees must check the gloves before donning by:** # **Inspecting for cracks, holes, or tears.** # **Performing a leak test by grasping the cuff of the glove quic kly such that air is**  **trapped inside the glove. Squeeze the glove to ensure that air ca nnot escape. If a**  **glove has any hole, crack, or tear, or has evidence of degradation to the material,**  **discard the glove. Employees must ensure that an ample supply of the proper glove**  **s are always available in the field.**

Decontamination **Employees should rinse gloves with water before removing. Gloves s hould be turned inside-out**  **during removal. Contaminated gloves are to be discarded.**

Glove Selection Chart Chemical(s) Glove Type **Solvents Nitrile (Sol-Vex) -Chlorinated PVA**  **Acids, Bases Nitrile (Sol-Vex)**

**Neoprene (Stanzoil) PVC Coated**  **Sample Collection Disposible Latex** 5.3 Protective Eyewear
Use & Selection **Chemical and physical hazards in the field have the potential to p roduce injuries to the eye and face.**  **These injuries could seriously impair or destroy vision, or permane ntly destroy facial skin. DEECO**  **provides eye and face protective equipment to employees at no cost. It is the responsibility of the Field Coordinator and Field Employees to ensure tha**  **t proper eye and face protection is available and worn in the work area. Contact**  **lenses may not be worn in areas requiring safety glasses.** **DEECO Health and Safety Plan Page 67 January 2010** Eyewear Hazards **Safety Glasses To be worn at all times on the work site or in designated "Eye** 

**Protection Required" areas. Safety Goggles To be worn whenever there is a potential of a che**  **mical splash**

**(e.g. handling or pouring solvents.) Face Shields To be worn when handling or pouring acids, bases, or other** 

**corrosive chemicals; when there is a potential of flying debris from drilling, cutting or grinding materials with power tools.**  Inspection **All safety glasses must meet the American National Standar ds Institute (ANSI) Standard Z87.1.**  **Safety glasses are required to have "Z87.1" stamped on the inside of the frame, or etched on the**  **lenses. DEECO will provide prescription safety glasses to those employees that require corrective**  **lenses. Safety glasses, goggles, or face shields that show visible si**  **gns of deterioration or damage should be repaired or discarded. If a damaged item is to be repaired, i**  **t should be placed in a plastic bag, sealed, and labeled "DAMAGED EQUIPMENT: FOR REPAIR".** 

Decontamination **All safety eyewear should be thoroughly cleaned with soap and wate r after each use in a**  **contaminated, or potentially contaminated, area.** 5.4 Protective Clothing **In many work situations it may be necessary for field personnel to wear full body protective clothing.**  **The Project Manager or Coordinator should identify the types of pr otective clothing that may be**  **necessary for a particular project, and ensure that the equipme nt is available at the work site. Brief**  **descriptions of the various protective clothing materials are given be low. In most situations, only**  **Tyvek or Saranex clothing will be necessary.** Standard Tyvek (non-porous) **Non-woven, olefin fiber fabric. Suitable for protection against m ost dusts, mists, and fumes.**  **Fabric melts at temperatures above 270** E **F. Should not be used to protect against solvent vapors or acid gases/fumes.**  Saranex Tyvek **Standard Tyvek which has one side coated with saranex plastic. This gives the clothing a**  **high level of resistance to most hazardous chemicals, including PCBs . Should not be used**  **in temperatures above 270** E **F. DEECO Health and Safety Plan Page 68 January 2010** 

Polyethylene Coated Tyvek **Standard Tyvek which has one side coated with polyethylene. This gives the clothing a high**  **level of resistance to most hazardous chemicals, including PCBs. M ore resistent to moisture,**  **and will protect individuals against chemical spills and spla shes better than the Saranex**  **Tyvek. Should not be used in temperatures above 270** E **F. Protective clothing is available in other materials, such as pol**  **yvinyl chloride, neoprene, Viton, and butyl rubber. These materials protect against a higher degr**  **ee of hazard than Field personnel would be expected to encounter. If the Project Manager or Coordinator f**  **eels that additional protection is required for a specific project, he/she should discuss clothing options with the S**  **.O.**

5.5 OSHA Levels of Protection
Use & Selection **Employees should select the level of personal protective equipment required for each individual**  **work site based on the current EPA guidelines below. Employees are not to perform tasks in the**  **work area if the proper personal protective equipment is not ava ilable or in good working condition.**  **At a minimum, employees must wear safety glasses and safet y shoes/boots at all work sites. DEECO**  **employees will not enter areas requiring Level A or Level B protection. All employees will be**  **trained on the proper use of protection equipment for Level C and Level D protect ion.** 

Levels of Protection **Level A - Highest level of respiratory, skin and eye protection is needed. Criteria inc**  **lude:**

# **High concentration of vapors, gases or particulates.** # **High potential for splash, immersion or potential exposure to hi ghly toxic**  **materials.** # **Confined or poorly-ventilated areas. Equipment:**  # **Supplied air respirator (pressure-demand SCBA or airline re spirator with** 

**escape bottle)** # **Fully encapsulating chemical resistent suit** # **Inner gloves, chemical resistent** # **Chemical resistent safety (steel-toe and shank) boots Optional Equipment includes coveralls, long cotton underwear, hard hat, disp**  **osable gloves and boot covers, cooling unit, 2-way radios.**  **Level B - Highest level of respiratory protection, lesser level of skin protecti**  **on. Criteria include:**

# **Atmospheres immediately dangerous to life and health (IDLH)** # **Oxygen deficient atmosphere (<20%).** # **Low potential for splash, immersion or potential exposure to highl y toxic**  **materials. DEECO Health and Safety Plan Page 69 January 2010** 

**Equipment:** # **Supplied air respirator (pressure-demand SCBA or airline res pirator with** 

**escape bottle)** # **Chemical resistent clothing** # **Outer gloves, chemical resistent** # **Inner gloves, chemical resistent** # **Chemical resistent safety (steel-toe and shank) boots Optional Equipment includes long cotton underwear, hard hat, disposable gloves and**  **boot covers, cooling unit, 2-way radios.**  **Level C - Conditions allow the use of air-purifying respirators. Criteria include:** 

# **Oxygen concentrations not less than 20%.** # **Concentrations of identified contaminants will be reduced by the respi rator**  **below the contaminants TLV, and the concentration is within the se rvice limit**  **of the canister/cartridge.** # **Concentrations of contaminants to not exceed IDLH levels.** # **Low potential for splash, immersion or potential exposure to highl y toxic**  **materials.** # **FID or PID measurements show concentrations only a few ppms above background.**  **Equipment:** # **Air-purifying, full-face respirator with appropriate canister or ca rtridges** 

# **Chemical resistent clothing** # **Outer gloves. Chemical resistent** # **Chemical resistent safety (steel-toe and shank) boots Optional Equipment includes long cotton underwear, hard hat, disposable gloves and**  **boot covers, escape mask, hard hat, 2-way radios.**  **Level D - No respiratory or skin hazards exist. Criteria include:** 

# **No contaminants present.** # **No potential for splash, immersion or potential exposure to any chemicals. Equipment:**  # **Coveralls or work clothing**

# **Safety shoes/boots** # **Safety glasses** # **Hard hat Optional Equipment includes gloves, face shield.** **DEECO Health and Safety Plan Page 70 January 2010**

5.5 Training for the Use Personal Protective Equipment **DEECO will provide training to each employee who is required to use PPE. Each s uch employee**  **will be trained to know when PPE is necessary, what PPE is necessary, how to properly don, doff,**  **adjust, and wear PPE, the limitations of the PPE, and the proper care, maintenance, useful life and**  **disposal of the PPE. Each affected employee will be required to demonstrate an underst**  **anding of the training and the ability to use PPE properly, before being allowed to perform work requi**  **ring the use of PPE. When DEECO has reason to believe that any affected employee who**  **has already been trained does not have the understanding and skill required, DEECO will retrain each such employee.**  **Circumstances where retraining is required include, but are not li mited to, situations where changes**  **in the workplace render previous training obsolete, changes in th e types of PPE to be used render**  **previous training obsolete, or inadequacies in an affected employee 's knowledge or use of assigned**  **PPE indicate that the employee has not retained the requisite understanding or skill**

**. DEECO will verify that each affected employee has received and**  **understood the required training through a written certification that contains the name of each emp**  **loyee trained, the date(s) of training, and that identifies the subject of the certification.** on value inme (ppmvden. If the tection limition limit inExhaustFlowrate(selectflowrateunits)Worksheet Title:HCl Emission Test Results Template Using Method 321Who Should Complete this Spreadsheet?Facilities that use Method 321 to test for HClCompanyName:FacilityName:Address:City:State:Kiln ID:Kiln Type:Indicate whether the kiln is wet, long dry, PH, PH/PCIn-line Raw Mill:Yes or NoControl Device Configuration:Enter all installed air pollution control devices hereParameter Sample #1 Sample #2 Sample #3 Test AverageUnits Units Other DescriptionTest Method UsedTest LocationNoteEnter HCl concentratiparts per million volucorrected to 7% oxygresults are below deteplease note the detectbrackets(e.g., [< 0.010]).Select approprfrom list. If othselected pleaseunits in columndry)st,iate uniter isdescribeH at right.Enter the name ofthe Test Method used.Indicate whether the testoccurred upstream ordownstream of a controldevice(s); list the controldevice(s)If kiln has an in-line raw mill,indicate raw mill status during tests(i.e., raw mill on or raw mill off).Provide any other informationsupporting information you think isnecessary about this test report.Sample Date (mm/dd/yyyy)HCl Concentrationppmvd @ 7% O2Exhaust Stream %Moisture%ExhaustFlowrate(selectflowrateunits)Exhaust Temperature(select temperature units)Sample Date(mm/dd/yyyy)HCl Concentrationppmvd@7% O2Exhaust Stream %Moisture%Exhaust Flowrate(select flowrate units)Exhaust Temperature(select temperature units)Notes:Peach shaded cells indicate areas where the user will enter a responsevalue in drvd) correcults are bete the deteExhaustFlowrate161400164100166000dscfmWorksheet Title:HCl Emission Test Results Template Using Method 321Who Should Complete this Spreadsheet?Facilities that use Method 321 to test for HClCompany Name:Holcim (US), Inc.Facility Name:AdaAddress:1100 West 18th StreetCity:AdaState:OKKiln ID:Long WetKiln Type:Indicate whether the kiln is wet, long dry, PH, PH/PCIn-line Raw Mill:Yes or No NOControl Device Configuration:ESPParameter Sample #1 Sample #2 e Sampl #3 Test AverageUnits Units Other DescriptionTest Method UsedTest LocationNoteEnter HCl concentrationper million volume (ppm7% oxygen. If the test resdetection limit, please nolimit in brackets(e.g., [< 0.010]).Select apprfrom list. Ifselected pleunits in coly partsted tolowctionopriate unitother isase describeumn H at right.Enter the name of the Test Method used.Indicate whether the testoccurred upstream ordownstream of a controldevice(s); list the controldevice(s)If kiln has an in-line raw mill, indicateraw mill status during tests (i.e., rawmill on or raw mill off). Provide anyother information supportinginformation you think is necessaryabout this test report.Sample Date (mm/dd/yyyy)3/12/20103/12/2010 3/12/2010HCl Concentration1.661.341.25 1.42 ppmvd @ 7% O2EPA Method321DownExhaust Stream %Moisture26.725.926.1%ExhaustFlowrate161400164100166000dscfmExhaust Temperature331331328Degree FSample Date(mm/dd/yyyy)HCl Concentrationppmvd@7% O2Exhaust Stream %Moisture%Exhaust Flowrate(select flowrate units)Exhaust Temperature(select temperature units)Notes:Peach shaded cells indicate areas where the user will enter a responseue in dry pcorrecteds are belowhe detectio255 253 253Worksheet Title:HCl Emission Test Results Template Using Method 321Who Should Complete this Spreadsheet?Facilities that use Method 321 to test for HClCompany Name:Holcim (US), Inc.Facility Name:Devils SlideAddress:6055 East Croydon RoadCity:MorganState:UtahKiln ID:Precalciner KilnKiln Type:Indicate whether the kiln is wet, long dry, PH, PH/PCIn-line Raw Mill:Yes or No YESControl Device Configuration:Fabric FilterParameter Sample #1 Sample #2 Sample #3 Test AverageUnits Units Other DescriptionTest Method UsedTest LocationNoteEnter HCl concentration valper million volume (ppmvd)7% oxygen. If the test resultdetection limit, please note tlimit in brackets(e.g., [< 0.010]).Select appropfrom list. If otselected pleasunits in columartstonriate unither ise describen H at right.Enter the name of the Test Method used.Indicate whether the testoccurred upstream ordownstream of a controldevice(s); list the controldevice(s)If kiln has an in-line raw mill,indicate raw mill status during tests(i.e., raw mill on or raw mill off).Provide any other informationsupporting information you think isnecessary about this test report.Sample Date (mm/dd/yyyy)2/24/20102/24/2010 2/24/2010HCl Concentration2.814.112.73 3.21 ppmvd @ 7%O2EPA Method 321DownMILL ONExhaust Stream %Moisture12.310.210.6%MILL ONExhaust Flowrate184800187100 188600dscfmMILL ONE hTxaust Temperature255253253DDegree FMILLNOSample Date(mm/dd/yyyy)2/25/20102/25/2010 2/25/2010HCl Concentration7.598.225.44 7.08ppmvd@7%O2EPA Method 321DownMILL OFFExhaust Stream %Moisture6.88.912.4%MILL OFFExhaust Flowrate189900187400 179500dscfmMILL OFFExhaust Temperature302304302Degree FMILL OFFNotes:Peach shaded cells indicate areas where the user will enter a responsevalue in d(ppmvd)If the testt, please notsExhaustFlowrate440300423500411900dscfmBOTHMILLONWorksheet Title:HCl Emission Test Results Template Using Method 321Who Should Complete this Spreadsheet?Facilities that use Method 321 to test for HClCompany Name:Holcim (US), Inc.Facility Name:Saint GenevieveAddress:2942 US Highway 61City:BloomsdaleState:MOKiln ID:PrecalcinerKiln Type:Indicate whether the kiln is wet, long dry, PH, PH/PCIn-line Raw Mill:Yes or No YESControl Device Configuration:Fabric Filter and Lime InjectionParameter Sample #1 Sample #2 Sample #3 Test AverageUnits Units Other DescriptionTest Method UsedTest LocationNoteEnter HCl concentrationparts per million volumecorrected to 7% oxygen.are below detection limidetection limit in bracke(e.g., [< 0.010]).Select approfrom list. Ifselected pleaunits in coluryresultste thepriate unitother isse describemn H at right.Enter the name of the Test Method used.Indicate whether the testoccurred upstream ordownstream of a controldevice(s); list the controldevice(s)If kiln has an in-line raw mill, indicateraw mill status during tests (i.e., rawmill on or raw mill off). Provide anyother information supportinginformation you think is necessaryabout this test report.Sample Date (mm/dd/yyyy)2/14/20102/14/2010 2/14/2010HCl Concentration[<0.23][<0.21][<0.23] [<0.22] ppmvd @ 7%O2EPA Method 321DownBOTH MILL ONExhaust Stream %Moisture12.712.912.8%BOTH MILL ONExhaustFlowrate440300423500411900dscfmBOTHMILLONExhaust Temperature197194192Degree FBOTH MILL ONBOTH MILL ONSample Date(mm/dd/yyyy)2/15/20102/15/2010 2/15/2010HCl Concentration2.384.143.62 3.38ppmvd@7%O2EPA Method 321BOTH MILL OFFExhaust Stream %Moisture7.48.17.3%BOTH MILL OFFExhaust Flowrate428300429600434800dscfmBOTH MILL OFFExhaust Temperature355367364(select temperature units)BOTH MILL OFFSample Date(mm/dd/yyyy)2/15/20102/15/2010 2/15/2010HCl Concentration0.781.121.24 1.04ppmvd@7%O2EPA Method 321One MILL ON and One MILL OFFExhaust Stream %Moisture10.911.110.5%One MILL ON and One MILL OFFExhaust Flowrate413900404300419100(select flowrate units)One MILL ON and One MILL OFFExhaust Temperature270272276(select temperature units)One MILL ON and One MILL OFFNotes:Peach shaded cells indicate areas where the user will enter a responseon value inme (ppmvden. If the tection limition limit inExhaustFlowrate(selectflowrateunits)Worksheet Title:HCl Emission Test Results Template Using Method 321Who Should Complete this Spreadsheet?Facilities that use Method 321 to test for HClCompanyName:FacilityName:Address:City:State:Kiln ID:Kiln Type:Indicate whether the kiln is wet, long dry, PH, PH/PCIn-line Raw Mill:Yes or NoControl Device Configuration:Enter all installed air pollution control devices hereParameter Sample #1 Sample #2 Sample #3 Test AverageUnits Units Other DescriptionTest Method UsedTest LocationNoteEnter HCl concentratiparts per million volucorrected to 7% oxygresults are below deteplease note the detectbrackets(e.g., [< 0.010]).Select approprfrom list. If othselected pleaseunits in columndry)st,iate uniter isdescribeH at right.Enter the name ofthe Test Method used.Indicate whether the testoccurred upstream ordownstream of a controldevice(s); list the controldevice(s)If kiln has an in-line raw mill,indicate raw mill status during tests(i.e., raw mill on or raw mill off).Provide any other informationsupporting information you think isnecessary about this test report.Sample Date (mm/dd/yyyy)HCl Concentrationppmvd @ 7% O2Exhaust Stream %Moisture%ExhaustFlowrate(selectflowrateunits)Exhaust Temperature(select temperature units)Sample Date(mm/dd/yyyy)HCl Concentrationppmvd@7% O2Exhaust Stream %Moisture%Exhaust Flowrate(select flowrate units)Exhaust Temperature(select temperature units)Notes:Peach shaded cells indicate areas where the user will enter a response**DEECO Inc. 3404 Lake Woodard Road**  **Raleigh, NC 27604 (919) 250-0285 (ph); (919) 250-1835 (Fax)**  **www.stacksampling.com**



## Site-Specific Test Plan U.S. EPA Information Collection Request

for Hydrogen Chloride Emissions

from Portland Cement Manufacturing Facilities

**Holcim (US) Inc. - Ste. Genevieve Plant 2942 US Highway 61**  **Bloomsdale, MO 63627**

Submitted By: DEECO, INC. 3404 Lake Woodard Road Raleigh, NC 27603 February 10, 2010

Proposed Test Date: February 13-15, 2010TABLE OF CONTENTS

Section Page **1.0 INTRODUCTION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1**  **1.1 Summary of Test Program . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1**  **1.2 Test Program Organization . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1** 
**2.0 SOURCE DESCRIPTION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3**  **2.1 Process Description . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3**  **2.2 Control Equipment Description . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4** 
**3.0 TEST PROGRAM . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5**  **3.1 Objectives . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5**  **3.2 Test Matrix . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5** 
**3.3 PROCESS PERFORMANCE INFORMATION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7**  **3.4 Test Coordination . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7** 
**4.0 SAMPLING LOCATIONS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9**  **4.1 Flue Gas Sampling Location . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9** 
**5.0 SAMPLING AND ANALYTICAL PROCEDURES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11**  **5.1 Test Methods . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11**  **5.2 Sampling Point Determination - EPA Method 1 . . . . . . . . . . . . . . . . . . . . . . . . . 11**  **5.3 Flue Gas Velocity and Volumetric Flow Rate - EPA Method 2 . . . . . . . . . . . . . 11**  **5.4 Outlet Flue Gas Composition - EPA Method 3A . . . . . . . . . . . . . . . . . . . . . . . . 11**  **5.5 Flue Gas Moisture Content - EPA Method 4 . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11**  **5.6 Oxygen, Carbon Dioxide, and Hydrogen Chloride - EPA Methods 3A and 321**

**. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12**  **5.6.1 Test Equipment Description . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12**  **5.6.2 Conditioning and Operational Test Periods . . . . . . . . . . . . . . . . . . . . . . . 14 5.6.3 Test Requirements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .**  **. . . . . 14 5.6.4 Test Procedures for EPA Method 3A . . . . . . . . . . . . . . . . . . . . . . . . . . . 14**  **5.6.4 Calibration Gases . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15**  **5.6.5 Test Procedures . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15**  **5.6.6 Data Acquisition . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16**  **5.7 Test Procedures for EPA Method 321 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16**  **6.0 QA/QC ACTIVITIES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18**  **6.1 QC PROCEDURES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18**  **6.1.1 Manual Sampling Equipment . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18**  **6.1.2 Manual Sampling Equipment Calibration . . . . . . . . . . . . . . . . . . . . . . . . 18**  **6.1.3 Manual Sampling Quality Control Procedures . . . . . . . . . . . . . . . . . . . . 23 7.0 REPORTING AND DATA REDUCTION REQUIREMENTS . . . . . . . . . . . . . .**  **. . . . . . . . 26 Format . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .**  **. . . . . . . . . . . . . . . . . 26 7.2 Data Reduction and Summary . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .**  **. . . . . 27**TABLE OF CONTENTS (continuerd)

Section Page **8.0 PLANT ENTRY AND SAFETY . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 28**  **8.1 Safety Responsibilities . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 28**  **8.2 Safety Program . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 28**  **8.3 Safety Requirements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 28** 
**9.0 PERSONNEL RESPONSIBILITIES AND TEST SCHEDULE . . . . . . . . . . . . . . . . . . . . . 29**  **9.1 Test Site Organization . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 29**  **9.2 Test Preparations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 29**  **9.3 Test Personnel Responsibilities and Detailed Schedule . . . . . . . . . . . . . . . . . . . 29** 

LIST OF TABLES

Table Page **TABLE 3.1 SUMMARY OF SAMPLING AND ANALYTICAL TEST METHODS . . . . . . 6**  **TABLE 3.2 PROGRAM OUTLINE AND TENTATIVE TEST SCHEDULE . . . . . . . . . . . . . 8**  **TABLE 6.1 SUMMARY QA/QC ACTIVITIES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 21**  **TABLE 7.1 EXAMPLE DATA SUMMARY TABLE FOR HYDROGEN CHLOR IDE** 

**EMISSION TEST RESULTS, HOLCIM (US) SAINT GENEVIEVE F ACILITY,**  **BOTH RAW MILLS OFF CONDITION; FEBRUARY 15, 2010 . . . . . . . . . . . 27**

LIST OF FIGURES Figure Page **Figure 1.1 Organization for Holcim (US) Inc. Saint Genevieve Facility HCl ICR Test Program** 

**. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2**  **Figure 4.1 Schematic of the Main Kiln/Raw Mill Stack sampling location . . . . . . . . . . . . . . . . 10**  **Figure 6.1 Example field data sheet for EPA Methods 2 and 4 . . . . . . . . . . . . . . . . . . . . . . . . . 19**  **Figure 6.2 Example field data sheet for EPA Method 3A . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 20** **HCl ICR Site-Specific Test Protocol Page: 1** 

**Holcim (US) Inc. Revision No: 0**  **Bloomsdale, Missouri Date: February 10, 2010**  

### 1.0 INTRODUCTION

1.1 Summary of Test Program **The U.S. Environmental Protection Agency (EPA), Office of Air Qua lity Planning and**  **Standards (OAQPS) has issued an Information Collection Request (ICR ) to Holcim (US), Inc**  **(Holcim). Under the authority of Section 114 of the Clean Air Act (C AA). The EPA is requesting**  **information on hydrogen chloride (HCl) emissions from nonhazardous waste-b urning kilns at**  **Portland cement manufacturing facilities. This request is in r esponse to comments from Portland**  **cement industry members and its trade association to EPA’s pro posal to amend the national emission**  **standards for hazardous air pollutants for Portland cement manufact uring (74 FR 21136 (May 6,**  **2009)). Holcim has retained DEECO Inc. (DEECO) to conduct the required emi**  **ssions testing. Testing for HCl will be conducted in accordance with EPA Method 321 -**  **Measurement of Gaseous Hydrogen Chloride Emissions At Portland Cement Kilns by Fourier T**  **ransform Infrared (FTIR) Spectroscopy.**  **The EPA has recognized that the manual sampling techniques for HCl (EPA Methods 26 and**  **26A) may have positive biases due to chloride salts (such as amm onium chloride) that, when**  **collected in the sampling train, for chloride ions (Cl -**  **) that is indistinguishable from the Cl -**  **ion formed upon collection of HCl. In addition, a negative bias may als**  **o exist due to condensation and/or removal of HCl on the filter and/or in the sampling probe.**  **Consequently, the EPA has decided that the FTIR measurement by EPA Method 321 is the prefer**  **red technique for determining the concentration of HCl emissions from nonhazardous waste-burning kilns**  **at Portland cement manufacturing facilities (Source http://www.epa.gov/ttn/atw/pcem/p**  **ortland.pdf). The Holcim facility located east of the township of Danby in**  **Ste. Genevieve County (designated as the Ste. Genevieve plant with the physical address**  **of 2942 US Highway 61 Bloomsdale, MO 63627) has been one of the Portland cement manufacturing f**  **acilities selected as part of the ICR. The source is identified as Cement Kiln/Raw Mill Stack (421/2-B**  **F1). HCl emission tests will be conducted at the main kiln/raw mill**  **stack during three conditions; both raw mills on (Mill On/On), one raw mill off (Mill Off/**  **On) and both raw mills off (Mill Off/Off).**  **Testing is anticipated to be conducted February 12-14, 2010.**

1.2 Test Program Organization **Figure 1.1 presents the test program organization, major lines of communication, and names**  **and phone numbers of responsible individuals. HCl ICR Site-Specific Test Protocol**  **Page: 2**

**Holcim (US) Inc. Revision No: 0**  **Bloomsdale, Missouri Date: February 10, 2010**  **EPA OAQPS, Sector Policies and Programs Division**  **Peter Tsirigotis Research Triangle Institute**  **Contract EP -D-06-118**

**EPA Sector Policies and Programs Division**  **Keith Barnett (919)541-5605**  **Barnett.Keitht@epa.gov Holcim (US), Inc.**  **Corporate Contacts Ruksana Mirza**  **or Hector Ybanez**  **Corporate Manager, Environmental**  **(214) 524 - 2814 Hector.Ybanez@holcim.com**  **Holcim (US), Inc. Environmental Contact**  **Timothy Schlosser (734)529-4118**  **Timothy.Schlosser@holcim.com**

EPA report data contact **Ron Meyers (919) 541-5407**  **myers.ron@epa.gov or**  **Barrett Parker (919) 541-5635**  **parker.barrett@epa.gov Holcim (US) Inc.**  **Ste. Genevieve Plant Mr. James Lunan**  **(636) 524-8184 James.Lunan@holcim.com**  EPA Test Method contact **Peter Westlin (919) 541-1058**  **westlin.peter@epa.gov**

**or Gary McAllister**  **(919) 541-1062 mcalister.gary@epa.gov**  **DEECO Project Manager Scott Steinsberger**  **(919)250-0285 deeco@deeco.com** 

**DEECO Field Team**

**Figure 1.1 Organization for Holcim (US) Inc. Saint Genevieve Facility HCl ICR Test Program** **HCl ICR Site-Specific Test Protocol Page: 3** 

**Holcim (US) Inc. Revision No: 0**  **Bloomsdale, Missouri Date: February 10, 2010**  

### 2.0 SOURCE DESCRIPTION 2.1 Process Description **The Ste. Genevieve plant has the annual clinker production capacity of 4,828,074 tons with**  **a Portland cement production capacity of 5,082,183 tons. Operational units tha t accommodate this**  **level of production include an on-site quarry, raw material storage, crushing and milling, solid fuel**  **(coal and petroleum coke) storage and milling, liquid fuel storage, one preheater/precalciner cement**  **kiln system, product milling, product storage, and loading and unloading systems. Cement manufacturing involves chemical and physical processing of l**  **arge quantities of raw materials. The raw materials used include sources of calcium, silica**  **, alumina and iron. These are the components necessary for the manufacture of the cement chemi**  **cals dicalcium silicate, tricalcium silicate, tricalcium aluminate, and tetra-calcium aluminoferri**  **te. The raw feed is prepared for use in the kiln system by sizing, grinding and blending the various raw mat**  **erials to produce the necessary mix for quality production. The prepared raw feed is introduced to t**  **he kiln system where it is physically and chemically transformed into clinker, the intermedia**  **te product of Portland cement. In the kiln system, the raw materials are exposed to tempera**  **tures reaching up to 3,500** E **F through a countercurrent process in the kiln and a co-current process in the pr**  **eheater. The raw materials are heated to 2,650**  E **F, the temperature required to produce quality clinker. Both on- site and off-site**  **sources supply raw materials for cement kiln feed at the Ste . Genevieve plant. Quarry resources**  **include limestone and shale deposits that will comprise part of the raw material blend to become**  **clinker, the principal product. Holcim will receive other raw m aterials from off-site suppliers at the**  **Ste. Genevieve plant by rail, truck, and barge via the Mississip pi River. Materials received from off**  **site may include limestone, iron ore, clay, bottom ash, fly ash, baux ite, diaspore, gypsum and other**  **materials as necessary. An important source of raw materia ls is nonhazardous waste materials from**  **other industries that have the proper chemical and physical propertie s to be used as a raw material**  **source. The Ste. Genevieve plant is designed for these types of m aterials as sources of calcium,**  **silica, alumina and iron. Preparation of raw materials, depe nding on its source and physical**  **properties, involves primary and secondary crushing, and screening, bl ending and grinding in the raw**  **mills prior to entrance into the preheater tower of the cement kiln system. Holcim uses coal and petroleum coke as the primary fuels for t**  **he cement manufacturing process at the Ste. Genevieve plant. Holcim uses coal mills t**  **o prepare raw coal/coke for firing in the precalciner and the kiln. Solid fuels are received at the fa**  **cility by truck, rail, and river barge. Liquid oils and similar non-hazardous materials are used as a seconda**  **ry fuel in critical situations such as start-up and back-up. The facility’s equipment design**  **also allows Holcim to beneficially use many other sources of energy bearing, non-hazardous waste materials**  **as supplemental fuel, such as whole or shredded tires, when available. The preheater/precalcine**  **r pyroprocess is a state-of-the-art design that features five-stage cyclone-type preheater tower**  **, low-NOx precalciner, and a rotary kiln. The preheater/precalciner portion of the system is located in a tal**  **l tower adjacent to the kiln. The low-NOx precalciner will be located at the base of the towe**  **r. The precalciner allows the burning fuel to be thoroughly mixed with the kiln feed. Excess heated air from t**  **he clinker cooler (tertiary air) will provide combustion air for the precalciner. Preheater/precalcin**  **er kilns feature greater thermal efficiency as compared to long dry or long wet kilns. This results**  **in significantly lower emissions and decreased fuel consumption per ton of clinker produced. To increase**  **energy efficiency even HCl ICR Site-Specific Test Protocol**  **Page: 4**

**Holcim (US) Inc. Revision No: 0**  **Bloomsdale, Missouri Date: February 10, 2010**  **further, hot exhaust gases from the preheater tower are utilize d to dry kiln feed in the raw mills and**  **fuel in the coal mill.** 2.2 Control Equipment Description **The emissions from the kiln are controlled by fabric filter ba ghouses. In addition lime**  **injection is used for additional acid gas control. HCl ICR Site-Specific Test Protocol**  **Page: 5**

**Holcim (US) Inc. Revision No: 0**  **Bloomsdale, Missouri Date: February 10, 2010**  

### 3.0 TEST PROGRAM

3.1 Objectives **Testing for HCl will be conducted in accordance with EPA Method 321 - Measureme nt of**  **Gaseous Hydrogen Chloride Emissions At Portland Cement Kilns by Four ier Transform Infrared**  **(FTIR) Spectroscopy. The EPA has recognized that the manual sampling techniques for HCl**  **(EPA Methods 26 and 26A) may have positive biases due to chloride salts (such as a**  **mmonium chloride) that, when collected in the sampling train, for chloride ions (Cl**  **- ) that is indistinguishable from the Cl**  **- ion**  **formed upon collection of HCl. In addition, a negative bias may als o exist due to condensation**  **and/or removal of HCl on the filter and/or in the sampling probe. Consequently, the EPA has**  **decided that the FTIR measurement by EPA Method 321 is the prefer red technique for determining**  **the concentration of HCl emissions from nonhazardous waste-burning kilns at Portland cement**  **manufacturing facilities (Source http://www.epa.gov/ttn/atw/pcem/p ortland.pdf).**  **The specific objectives in order of priority are:**

C **Measure the emissions of HCl (EPA Method 321) from the Cement Kil n/Raw Mill Stack**  **during three conditions; both raw mills on (Mill On/On), one raw mill off (Mill Off/On) and**  **both raw mills off (Mill Off/Off), and**

C **Concurrent with the HCl measurements, measure the Cement Kiln/Ra w Mill Stack**  **volumetric flow rate (EPA Methods 1 and 2), the Cement Kiln/Raw Mi ll Stack oxygen and**  **carbon dioxide content (EPA Method3A), and the Cement Kiln/Raw Mill Stack moisture**  **content. Relevant process information will be collected by plant pers**  **onnel in conjunction with the testing program. The raw process data will be presented a**  **s collected in the appendices of the final report.**  3.2 Test Matrix **Table 3.1 presents the sampling and analytical matrix. HCl ICR Site-Specific Test Protocol**  **Page: 6**

**Holcim (US) Inc. Revision No: 0**  **Bloomsdale, Missouri Date: February 10, 2010** 

TABLE 3.1 SUMMARY OF SAMPLING AND ANALYTICAL TEST METHODS

Test Parameter Sampling

Method Sample Type Sampling Frequency Analytical Method Measurement Technique

**Volumetric Flow Rate**  **EPA Methods**

**1 and 2 Traverse points;** 

**thermocouple and Pitot tube**  **Concurrent**

**with each Method 321**  **test EPA Method 2** 

**(40 CFR 60, App A) Thermocouple**  **readout and manometer**  **Oxygen and Carbon**  **Dioxide EPA Method** 

**3A Extractive** 

**instrumental sample**  **Concurrent**

**with each Method 321**  **test EPA Method 3A** 

**(40 CFR 60, App A) Paramagnetic**  **for O 2**  **and NDIR for CO**  **2**

**Moisture EPA Method** 

**4 Traverse points;** 

**Condensation Concurrent** 

**with each Method 321**  **test EPA Method 4** 

**(40 CFR 60, App A) Gravimetric** 

**Hydrogen Chloride**  **EPA Method**

**321 Extractive** 

**instrumental sample**  **Three 60-**

**minute test runs per**  **condition EPA Method 321** 

**(40 CFR 63, App A) Fourier**  **Transform Infrared**  **(FTIR) spectrometry** **HCl ICR Site-Specific Test Protocol Page: 7** 

**Holcim (US) Inc. Revision No: 0**  **Bloomsdale, Missouri Date: February 10, 2010**  3.3 PROCESS PERFORMANCE INFORMATION **Plant personnel in conjunction with the testing program will colle ct process information. The**  **raw process data will be presented as collected in the appendices of the f inal report.** 

3.4 Test Coordination **Mr. James Lunan, the Holcim facility contact, will serve as the t est coordinator. He will be**  **responsible for: 1. Scheduling the start of all testing;**  **2. Principal contact with the agency officials concerning the tests; 3. Principal contact with DEECO concerning the tests;**  **4. Recording the process data during the testing; and 5. Providing copies of any field test data to the agency.**  **A tentative test schedule is shown in table 3.2. HCl ICR Site-Specific Test Protocol**  **Page: 8**

**Holcim (US) Inc. Revision No: 0**  **Bloomsdale, Missouri Date: February 10, 2010**  TABLE 3.2 PROGRAM OUTLINE AND TENTATIVE TEST SCHEDULE Sampling Location Parameter(s) Measured Sampling Method Number of Runs

and Duration Length of

Day(s) Day 1 - February 13, 2010 **Arrive on-site and set up test equipment 8 hours** Days 2 & 3 - February 14-15, 2010 **Kiln Stack Flue Gas Flowrate EPA Methods 1, 2, 4 Three 60-minute**  **runs per condition (Mill On/On, Mill**  **On/Off, and Mill Off/Off)**  **10 hours O**  **2 /CO**  **2 EPA Method 3A**  **HCl EPA Method 321** Day 4 - February 16, 2010 **Contingency Day HCl ICR Site-Specific Test Protocol**  **Page: 9**

**Holcim (US) Inc. Revision No: 0**  **Bloomsdale, Missouri Date: February 10, 2010**  

### 4.0 SAMPLING LOCATIONS

4.1 Flue Gas Sampling Location **The kiln/raw mill stack is a vertically-oriented circular st ack with an inside diameter of**  **approximately 219". The stack gas sampling ports are located a pproximately 146.7' (approximately**  **8.0 duct diameters) above the closest disturbance and approximately 147.3' (approximately 8.1 duct**  **diameters) from the stack outlet. The sampling location meets the minimum specifications for**  **selection of a measurement site as outlined in EPA Method 1. A schematic of the Main Kiln/Raw Mill Stack sampling location is shown in Figur**  **e 4.1 HCl ICR Site-Specific Test Protocol**  **Page: 10**

**Holcim (US) Inc. Revision No: 0**  **Bloomsdale, Missouri Date: February 10, 2010** 

**Figure 4.1 Schematic of the Main Kiln/Raw Mill Stack sampling location. HCl ICR Site-Specific Test Protocol**  **Page: 11**

**Holcim (US) Inc. Revision No: 0**  **Bloomsdale, Missouri Date: February 10, 2010** 



### 5.0 SAMPLING AND ANALYTICAL PROCEDURES

5.1 Test Methods **This section contains a brief description of the sampling and analyti cal procedures for each**  **method that will be employed during the test program. All equipm ent, procedures, and quality**  **assurance measures necessary for completion of the test progra m will meet or exceed the**  **specifications of the appropriate methods. Any deviations fr om the methods to ensure quality**  **representativeness of the results are also discussed.** 5.2 Sampling Point Determination - EPA Method 1 **The number and location of the sampling or traverse points will be determined according to**  **the procedures outlined in EPA Method 1. The sample location has alre ady been confirmed to meet**  **EPA Method 1 based on previous source tests. All points will be at least 1.0 inc hes from the stack**  **wall, per Method 1. For the main kiln stack, a total of 12 velocity/i sokinetic traverse points will be**  **used, with six points on each of the two 90o axes** 5.3 Flue Gas Velocity and Volumetric Flow Rate - EPA Method 2 **The flue gas velocity and volumetric flow rate will be determi ned according to the procedures**  **outlined in EPA Method 2. Velocity measurements will be made using type S pitot tubes conforming**  **to the calibration specifications outlined in EPA Method 2, Secti on 10.1. Each Type-S pitot tube,**  **calibrated according to these standards, will have an assigned coef ficient. Differential pressures will**  **be measured with Magnehelic gauges of appropriate range or with fluid manometers. Effluent gas**  **temperatures will be measured with chromel-alumel thermocoupl es equipped with digital readouts.**  5.4 Outlet Flue Gas Composition - EPA Method 3A **Outlet flue gas analysis for oxygen (O 2**  **) and carbon dioxide (CO 2**  **) concentrations, and the calculation of percent excess air and flue gas dry molecular w**  **eight will be performed in accordance with EPA Method 3A. Refer to Section 5.6 for more information** 

5.5 Flue Gas Moisture Content - EPA Method 4 **The flue gas moisture content will be determined in conjunction wit h each sampling run and**  **according to the sampling and analytical procedures outlined in EPA Method 4. The impingers will**  **be connected in series, and contained in an ice bath in order to assure condensation of t he moisture**  **in the flue gas stream. Any moisture that is not condensed in the i mpingers is captured in the silica**  **gel, therefore all moisture can be weighed and entered into moisture content calc ulations.** **HCl ICR Site-Specific Test Protocol Page: 12** 

**Holcim (US) Inc. Revision No: 0**  **Bloomsdale, Missouri Date: February 10, 2010**  5.6 Oxygen, Carbon Dioxide, and Hydrogen Chloride - EPA Methods 3A and 321 **A CEM system will be used to determine oxygen and carbon dioxide concentrations and**  **hydrogen chloride concentrations on the Main Kiln/Raw Mill stack. The procedures used in meeting**  **these requirements are detailed below.** 5.6.1 Test Equipment Description **The instrumentation and all sampling and analytical procedures that will be used by DEECO**  **for the HCl ICR testing will conform with the requirements of E PA Test Methods 3A and 321 using**  **FTIR. For HCl, the extractive system requires that the effluent gas**  **sample be filtered and maintained at a minimum of 356°F (180°C) prior to being delivered to the FTIR s**  **ample cell. The FTIR sample cell will also be maintained at 356°F. The gas sample will**  **be drawn through the extractive system and the FTIR cell using a heated sample pump. The extractive**  **system will be equipped with a glass lined probe also heated to a minimum of 356°F. The probe will**  **be of sufficient length to reach a minimum of three traverse points at 17, 50, and 83 percent of the duct diameter or 0.4, 1.2,**  **and 2.0 meters from the stack or duct wall, which ever is less. All c**  **omponents of the sampling system which contact the sample will be either of glass, stainless steel, or Teflon**  **The extracted gas sample exiting the heated sample pump wi ll be conditioned to remove**  **moisture with an ice water-cooled condenser. A gas distribution manifold wil l be used to deliver a**  **representative sample of flue gas to oxygen and carbon dioxide analyzers. Fourier Transform Infrared (FTIR) spectroscopy for Hydrogen Chl**  **oride - FTIR spectroscopy**  **measures vapor phase organic or inorganic compounds which absorb ener gy in the mid-infrared**  **spectral region, about 400 to 4000 cm -1**  **(25 to 2.5 μm). Continuous measurement is made by matching sample absorbance bands with bands in reference spect**  **ra, and comparing sample band intensities with reference band intensities.**  **The principle limitation to FTIR spectroscopy are the pres ence of interfering compounds that**  **also absorb energy in the mid-infrared spectral region. In a c ement kiln stack gas matrix, water vapor**  **(H 2**  **O) and carbon dioxide (CO 2**  **) are the primary interferents that must be incorporated i nto the**  **identification and quantitation method. By choosing the proper analytical region(s) for the HCl spectra, the eff**  **ect of the interfering compounds can be minimized. The analytical regions will be sele**  **cted based on examination of the actual stack gas matrix. (It should be noted that the analytica**  **l region provided as an example in EPA Method 321 (2679-2840 cm**  **-1 ) does not correspond with the entire analytical region for HCl (2600-**  **3100 cm -1**  **). The example cited in Method 321 appears to have been copied from the formaldehyde**  **analytical region used as an example in Method 318.) The FTIR software performs the computation for a single compound b**  **y subtracting all the other compounds (interferants and target) from the absorbance spec**  **tra and quantifies the single compound based on the remain absorbance. The FTIR software provides**  **a Standard Error Calculation (SEC) value that is an indication of how well the identi**  **fication and quantitation has been performed. A high SEC indicates that other interferants have not b**  **een accounted for in the analysis HCl ICR Site-Specific Test Protocol**  **Page: 13**

**Holcim (US) Inc. Revision No: 0**  **Bloomsdale, Missouri Date: February 10, 2010**  **method, and a low SEC is indicative of greater confidence mesurement . Typically, if the reported**  **SEC is greater than half the reported concentration then the results is suspect**

**. A MIDAC I-Series FTIR will be used to determine HCl concent**  **rations according to EPA Method 321. Infrared absorption spectroscopy is performed by directing an infr**  **ared beam through a sample to a detector. The frequency-dependent infrared absorbanc**  **e of the sample is measured by comparing this detector signal (single beam spectrum) to a signal**  **obtained without a sample in the beam path (background). Most molecules absorb infrared radiation and the a**  **bsorbance occurs in a characteristic and reproducible pattern. The infrared spectrum**  **measures fundamental molecular properties and a compound can be identified from its infrared sp**  **ectrum alone. Within constraints, there is a linear relationship between infrared absorption a**  **nd compound concentration. If this frequency dependent relationship (absorptivity) is known (measured),**  **it can be used to determine compound concentration in a sample mixture.**  **Absorptivity is measured by preparing, in the laboratory, standa rd samples of compounds at**  **known concentrations and measuring the FTIR "reference spectra" of these standard samples. These**  **"reference spectra" are then used in sample analysis: (1) compounds are detected by matching sample**  **absorbance bands with bands in reference spectra, and (2) concentra tions are measured by comparing**  **sample band intensities with reference band intensities. Reference spectra for hydrogen chloride and sulfur hexafluoride will**  **be generated from commercially-available calibration gas cylinders. The EPA**  **reference spectra available from the EPA’s Emission Measurement Center are not representative of** **the concentrations (at 189.5 ppm meters and 497.3 ppm-meters) being measured. HCl reference spe**  **ctra at 2 ppm and 5 ppm (16.3 ppm-meters and 40.8 ppm-meters) will be used. Secondly, higher resol**  **ution spectra, compared to the EPA reference spectra, will be necessary due to the low**  **HCl concentrations that are expected and the high moisture levels (up to 35%) that will be encountered. Thir**  **dly, errors have been reported for certain EPA reference spectra, so the entire EPA reference spectra da**  **ta base should be suspect. CAI Model 200 O**  **2 /CO**  **2 Analyzer**  **- The CAI Model 200 O 2**  **/CO 2**  **analyzer houses two measurement principles in one instrument. The oxygen concentrations are measure**  **d using the parapneumatic technique. Because of its sp3 electron orbital distribution, an oxy**  **gen molecule has an unpaired electron and hence displays a magnetic orientation. Since other el**  **ements that display this magnetic phenomenon are not common gasses at normal temperatures, the parap**  **neumatic measurement technique is virtually specific for oxygen. The sample gas flows t**  **hrough a detection cell located in a very strong magnetic field. The magnetic nature of the oxygen cause**  **s the oxygen to move to one side of the detection cell, inducing a pressure differential prop**  **ortional to the oxygen concentration in the detector cell. The analyzer measures this pressure di**  **fferential, converts the pressure differential to an electrical signal, and sends the results as output.**  **The carbon dioxide concentrations are measured using a single -beam photometric system with**  **a micro flow sensor detector. The micro flow detector is a sea led unit filled with carbon dioxide.The**  **instrument consists of an infrared light source, a chopper, a measur ing cell and a micro flow detector**  **filled with carbon dioxide. The infrared light emitted backward is reflected by a reflecting surface**  **and is added to the infrared light emitted forward. Arranged betwe en the infrared light source and**  **the measuring cell is a chopper blade which rotates to modulate the infrared light beam at regular**  **frequency. The modulated infrared light beam thus formed passes thr ough the measuring cell filled**  **with a sample gas where the light energy is partially ab sorbed or attenuated before it reaches the front** **HCl ICR Site-Specific Test Protocol Page: 14** 

**Holcim (US) Inc. Revision No: 0**  **Bloomsdale, Missouri Date: February 10, 2010**  **chamber of the detector. Both the front and rear chambers of the detector are filled with the gas**  **component to be measured. The infrared light energy is partiall y absorbed in the front chamber and**  **residual light is absorbed in the rear chamber, thereby incre asing the pressure in both chambers.**  **Since the detector is designed to produce a pressure difference b etween the front and rear chambers,**  **a slight gas flow is produced through a path connecting these chambe rs with each other. This slight**  **flow is converted into an AC electrical signal by a micro flow sensor.**

5.6.2 Conditioning and Operational Test Periods **The conditioning and operational test periods will be complete d and sampling commenced**  **once all monitors are found to be acceptable.** 5.6.3 Test Requirements **DEECO's extractive measurement system and all sampling and analytical procedures for**  **testing will conform to the requirements of EPA Methods 2, 3A, and 4 of 40 CFR 60 and EPA**  **Method 321 of 40 CFR 63. The extractive monitors require that the effluent gas sample b**  **e conditioned to eliminate any possible interference (water vapor and particulate matter)**  **before being transported and injected into each analyzer. All components of the sampling system that conta**  **ct the sample are Type 316 stainless steel, glass, or Teflon.**  **A heated probe with an in-stack particulate filter, heated sa mple lines, moisture removal trap,**  **a sample pump, and distribution manifold board are used to deliver a represe ntative sample of flue**  **gas to the analyzers. The sampling probes are constructed of 316 stainless steel and are heated**  **electrically to maintain the sample temperature above the dew point. The sample acquisition and conditioning system also includes two inje**  **ction ports: (1) immediately upstream of the analyzers for analyzer lineari**  **ty checks, and (2) at the outlet of the probe for the sampling system bias and calibration drift checks. Thi**  **s arrangement provides both ease in checking the analyzer performance and a means of evaluating the entire monitoring**  **system.** 5.6.4 Test Procedures for EPA Method 3A **All analyzers will be subjected to an interference check sim ilar to the procedures in Section**  **5.4 of EPA Method 20. During calibration, all analyzers’ response wi ll be noted while introducing**  **each calibration gas. If the sum of the interference responses of the test gases for any of the analyzers**  **is greater than 2 percent of the applicable span value, correct ive measures on the analyzer will be**  **taken, up to and including replacement of the analyzer. Calibration procedures will be performed in accordance with EPA**  **methodology. Analyzers will be calibrated before and after each test and a calibr**  **ation check will be done between each test run.** **HCl ICR Site-Specific Test Protocol Page: 15** 

**Holcim (US) Inc. Revision No: 0**  **Bloomsdale, Missouri Date: February 10, 2010**  **The pretest calibrations will consist of the following steps: • Internal (direct) calibration of each analyzer to adjust cal**  **ibration and check linearity. • External (through the entire sampling system) calibration to**  **check the system bias on zero and span gases.**  **The post test calibration will consist of an external system bias cal ibration check.** 
5.6.4.1 Internal Calibration **- Each analyzer will be calibrated using a certified zer o and span (mid**  **or high range as necessary) gas. Zero and span gases will be directed to each analyzer through the**  **appropriate plumbing, the calibration gas flow rates will b e adjusted to the correct flow rate and the**  **analyzer will be adjusted with the appropriate span pot. After the analyzer is properly adjusted the**  **linearity will be checked using a mid range calibration gas. The maximum allowable limit for**  **linearity is 2% of the analyzer range. All analyzers will be shown to be linear within these limits**  **before proceeding.**
5.6.3.2 External Calibration **- The external calibration bias check will be performed by placing the**  **CEM system in the sampling mode and injecting a zero and span g as into the sample line at the probe**  **exit. This check will show if there was any sampling system related bias, and also served as a check**  **of the integrity of the sample line.**
5.6.4 Calibration Gases **DEECO will use EPA Protocol #1 gases for calibration as requir ed by the various reference**  **methods used in this test program. Calibration gases will be selected from previous experience with**  **similar sources and/or from information obtained from the facilit y engineer prior to sampling. Audit**  **gases, if available from federal or state agencies, will be analyzed.**
5.6.5 Test Procedures **At the completion of the pretest calibration routine, the CEM sy stem will be ready for**  **operation. No further adjustments of sample flow rates, analyz er zero or span adjustments, or other**  **critical CEM operating parameters will be made until te sting and post test calibration are complete.**  **The CEMs will be allowed to at least 21 minutes to complete e ach test run. At the completion for**  **each run, calibration gases nearest to the measured emission le vels will be used to check each**  **instrument. During each sampling run, a sampling traverse will be perfor**  **med to ensure the absence of stratification. Traverse points will be selected that assur**  **e acquisition of representative samples over the stack or duct cross section. A minimum requirement is the esta**  **blishment of a "measurement line" that passes through the centroidal area and in the direction of any e**  **xpected stratification. If this line interferes with the CEM measurements, the line will be displ**  **aced up to 30 cm (12 in.) (or 5 percent of the equivalent diameter of the cross section, whichever is less)**  **from the centroidal area. Per Section 6.5.6.3(a) of 40 CFR 75, three traverse points will be located 16.7,**  **50.0, and 83.3 percent of the measurement line, and measured equally during each run. Alternatively, per Se**  **ction 6.5.6.3(b) of 40 CFR 75, a single sampling point may be used if the concentra**  **tion of each compound at each individual traverse point differs by no more than ±5.0 percent from t**  **he arithmetic average concentration for all traverse points.** **HCl ICR Site-Specific Test Protocol Page: 16** 

**Holcim (US) Inc. Revision No: 0**  **Bloomsdale, Missouri Date: February 10, 2010**  **Concurrent measurements of flow following EPA Methods 1, 2, 3A, and 4 (Sec tions 5.1**  **through 5.5) will be used to determine flue gas emission rates of all target comp ounds.**  5.6.6 Data Acquisition **Data will be recorded on two separate devices. A hard copy wi ll be obtained using a Molytek**  **2702 strip chart recorder. Data will also be recorded to the hard disk of an IBM compatible computer**  **utilizing the serial output of the Molytek recorder in conjunction wi th custom software. Data for each**  **of the analyzers will be sampled each second with a one-minute a verage being written to disk. Data**  **will be further averaged over the test period and corrected f or calibration error and drift using a**  **spreadsheet program.**

5.7 Test Procedures for EPA Method 321 **The FTIR optics and sample cell will be purged with nitrog en overnight. A backgroung**  **spectra will be collected will purging nitrogen thorough the cel l at a flow rate low enough that the cell**  **pressure is not elevated above ambient pressure. Next an ethy lene Calibration Transfer Standard**  **(CTS) will be passed thorough the cell, again at a flow rate low enough that the cell pressure is not**  **elevated above ambient pressure, and spectra will be collecte d of the CTS gas. By setting the cell**  **pressure in the software to reflect the ambient pressure, the path length can be verified and adjusted**  **as needed. As part of the HCl analyte spiking procedure, the calibration g**  **as mixture containing HCl and sulfur hexafluoride (SF**  **6 ) will then be passed directly to the cell, again at a flow**  **rate low enough that the cell pressure is not elevated above ambient pressure.**  **This will establish the undiluted concentration of the HCl/SF**  **6 mixture to be used in the analyte spike recovery calculations.**  **Next the heated sample line will be connected directly to the sample cell, and stack gas will**  **be drawn through the cell prior to the pretest analyte spiking. The first step in the analyte spiking will be to send the CTS**  **to the sample probe and back through the sampling system. Spectra of the CTS gas will be**  **collected and the cell pressure setting in the software will be adjusted as needed to provide the correct CTS reading.**  **After the CTS check is completed, stack gas will again be sa mpled to provide a pre-spike**  **native concentration of HCl. Next the HCl/SF**  **6 gas mixture will be directed to the sample probe at a f**  **low rate approximately 10% of the total sample rate such that the stack**  **gas provides a nominal 10-fold dilution of the analyte spike. Once a satisfactory spike recovery**  **of 70%-130% has been is achieved, the HCl/SF**  **6 gas mixture will be turned off. The HCl/SF**  **6 spike will be purged from the system and**  **additional spectra will be collected from the stack gas to det ermine the post spike concentration of**  **the native HCl. HCl ICR Site-Specific Test Protocol**  **Page: 17**

**Holcim (US) Inc. Revision No: 0**  **Bloomsdale, Missouri Date: February 10, 2010**  **It should be noted that there are errors in the Method 321 equation used to calculate the**  **analyte spike recovery. Consequently the following correct equation will be used;**



### % R C C DF C DF t n

s 

### = − −      

× × **1 1** 

**1 100** 

**%R = Spike Recovery C**  **t = Concentration of the total HCl (spike plus native), ppm,**  **C n**  **= Average concentration of the native HCl (pre and post spike), ppm, C**  **s = Concentration of the HCl spike, ppm; and**  **DF = Ratio of the undiluted SF 6**  **tracer gas concentration to the diluted SF 6**  **measured during**

**analyte spiking HCl ICR Site-Specific Test Protocol**  **Page: 18**

**Holcim (US) Inc. Revision No: 0**  **Bloomsdale, Missouri Date: February 10, 2010**  

### 6.0 QA/QC ACTIVITIES 6.1 QC PROCEDURES **Example data sheets for EPA Methods 2 and 4 and EPA Method 3A are p rovided in Figures**  **6.1 and 6.2. Specific QA/QC parameters for each method is provided in Tabl**  **e 6.1 and described in detail below.**  6.1.1 Manual Sampling Equipment **Each item of field test equipment will be assigned a unique, per manent identification number.**  **An effective preventative maintenance program is necessary to ensure data quality. Each item of**  **equipment returning from the field will be inspected before it is returned to storage. During the**  **course of these inspections, items are cleaned, repaired, reconditi oned, and recalibrated where**  **necessary. Each item of equipment transported to the field for this test pr**  **ogram will be inspected again before being packed to detect equipment problems which may orig**  **inate during periods of storage. This minimizes lost time on the job site due to equipment failure.**  **Occasional equipment failure in the field is unavoidable despite t he most rigorous inspection**  **and maintenance procedures. For this reason, replacement equipment f or all critical sampling train**  **components will be transported to the job site.** 6.1.2 Manual Sampling Equipment Calibration **New items for which calibration is required will be calibra ted before initial field use.**  **Equipment whose calibration status may change with use or time w ill be inspected in the field before**  **testing begins and again upon return from each field use. When an i tem of equipment is found to be**  **out of calibration, it will be repaired and recalibrated or re tired from service. All equipment will be**  **periodically recalibrated in full, regardless of the outcome of these regula r inspections.**  **Calibrations will be conducted in a manner, and at a frequency, which meets or exceeds U.S.**  **EPA specifications. The calibration procedures outlined in the EP A Methods will be followed.**  **When these methods are inapplicable, methods such as those prescrib ed by the American Society for**  **Testing Materials (ASTM) will be used. Data obtained during calibrations will be recorded on standardize**  **d forms, which will be checked for completeness and accuracy by the quality assurance ma**  **nager. Data reduction and subsequent calculations will be performed using computer facili**  **ties. Calculations will be checked at least twice for accuracy. Copies of calibration forms will be incl**  **uded in the final test report. Emissions sampling equipment requiring calibration includes pitot**  **tubes, pressure gauges, thermometers, dry gas meters and barometers. The following sec**  **tions elaborate on the calibration procedures to be followed for these items of equipment.** **HCl ICR Site-Specific Test Protocol Page: 19** 

**Holcim (US) Inc. Revision No: 0**  **Bloomsdale, Missouri Date: February 10, 2010** 

**Flow rate and Moisture Measurement Data Sheet** Plant and City Date Sampling Location Sample Type Run N o.

Operator Barometric

Pressure (Pb) (In. Hg) Static

Press (in. H2O) Ambient

Temp (deg. F) Stack

ID (In.) Pitot

Cp DGM Box No. DGM delta H@ DGM Cal

Factor (gamma) Probe

ID No. **EPA Method 3/3A Data EPA Method 4 Impinger Weights Oxygen, % Impinger 1 2 3 Sil.Gel**  **Carbon Dioxide, % Final Wt., g Color**  **Nitrogen, % Initial Wt., g % Spent**  **Net Wt., g Total Collected , g**  **EPA Method 2 Data EPA Method 4 Sampling Data**

Run Time (24 hr) Port/Point

ID Pitot

delta P (in. H2O) Stack

Temp (deg. F) Run Time

(24 hr) DGM Reading (cu.ft.) DGM delta H (in. H2O) DGM

Temps (deg. F) Exit

Temp (deg. F) Sample

Train Vac. (In. Hg)

**Initial Leak Rate cfm @ “Hg Final Leak Rate cfm @ “Hg** 

**Pitot Leak Check**

**Figure 6.1 Example field data sheet for EPA Methods 2 and 4 HCl ICR Site-Specific Test Protocol**  **Page: 20**

**Holcim (US) Inc. Revision No: 0**  **Bloomsdale, Missouri Date: February 10, 2010**  **Plant and City Test Location Date Operator**

**Cylinder ID**  **Gas**

**Type Value Internal**  **Response Cal** 

**Error Run No. Run Time** 

**Pre Run Bias**  **Percent**

**Bias Post Run** 

**Bias Percent** 

**Bias Percent** 

**Drift O**  **2 Zero Zero N**  **2 CC5134 O**  **2 Mid 11.9%**  **CC117302 O 2**  **Span 21.9%**

**CO 2**  **Zero Zero N 2**  **CC5134 CO 2**  **Mid 20.4% CC117302 CO**  **2 Span 35.5%** 

**Figure 6.2 Example field data sheet for EPA Method 3A HCl ICR Site-Specific Test Protocol**  **Page: 21**

**Holcim (US) Inc. Revision No: 0**  **Bloomsdale, Missouri Date: February 10, 2010**  TABLE 6.1 SUMMARY QA/QC ACTIVITIES Test Equipment QC Parameter Target **Volumetric Flow Rate Measurement Pitot Tube Pitot Geometry Within Specifications**  **Thermocouple <1.5% absolute Pitot Leak Check stable 15 sec at**  $ **4 in. WC Dry Gas Meters for Particulate Sampling**  **Dry Gas Meters Initial Calibration 0.95** # **γ** # **1.05 individual γ RSD**  # **2% Post Test Calibration Check Post test γ**  # **5% Post Test Leak Checks <2% of sample rate**  **EPA Method 3A Initial Calibration Zero Gas <2% of Span Gas**  **Mid Range Gas <2% of Span Gas Span Gas <2% of Span Gas**  **Bias Checks Zero Gas <5% of Span Gas Mid Range Gas <5% of Span Gas**  **Drift Zero Gas <5% of Span Gas Mid Range Gas <5% of Span Gas**  **Method 321 for Hydrogen Chloride Pre/Post CTS Calibration Precision Pre and post quant**  **ification** # **5% RSD Direct HCl Calibration Precision Duplicate measuremen**  **t** # **5% RSD HCl Analyte Spike System Validation Spike Recovery 70**  **% - 130% HCl ICR Site-Specific Test Protocol**  **Page: 22**

**Holcim (US) Inc. Revision No: 0**  **Bloomsdale, Missouri Date: February 10, 2010**  A: Pitot Tubes. **All Type S pitot tubes used, whether separate or attached to a sampling**  **probe, will be constructed in-house or by a third-party vendor. Eac h new pitot will be**  **calibrated in accordance with Section 10.1 of EPA Method 2. Each Type -S pitot tube,**  **calibrated according to these standards, will have an assigned coe fficient. This**  **coefficient should not change as long as the pitot tube is not damaged. Each pitot tube will be inspected visually upon return f**  **rom the field. If a cursory inspection indicates damage or raises doubt that the pitot rema**  **ins in accordance with the EPA geometry standards, the pitot tube will be refurbis**  **hed as needed and recalibrated.**  B: Differential Pressure Gauge. **All meter consoles used are equipped with 10-inch water column (W.C.) inclined-vertical manometers. Fluid manometers**  **do not require calibration other than leak checks. Manometers will be leak chec**  **ked in the field prior to each test series, and again upon return from the field.**  C: Impinger Thermometer. **Prior to the start of testing, the thermocouple used to monitor the temperature of the gas leaving the last impinger w**  **ill be compared with a mercury-in-glass thermometer which meets ASTM E-1 No. 63F spec**  **ifications. The impinger thermocouple is replaced if it does not agree within**  **2** E **F of the reference thermometer. After each field use, the thermocouple will be c**  **hecked per EPA Alt-011 procedures.**  D: Dry Gas Meter Thermometer. **The thermocouple used to measure the temperature of the metered gas sample will be checked prior to initial f**  **ield use against an ASTM mercury-in-glass thermometer. The dry gas meter thermocouple**  **is acceptable if the values agree within ±2**  E **F. Thermocouples not meeting this requirement will be replaced. After each field use, the thermocouple will be checked**  **per EPA Alt-0011 procedures.**  E: Flue Gas Temperature Sensor. **All thermocouples employed for the measurement of flue gas temperature are calibrated upon receipt. Initi**  **al calibrations will be performed at three points (ice bath, boiling water, and hot oil).**  **An ASTM mercury-in glass thermometer will be used as a reference. The thermocou**  **ple is acceptable if the agreement is within 1.5 percent (absolute) at each of the thre**  **e calibration points. After each field use, the thermocouple will be checked per EPA**  **Alt-011 procedures. Before each field use, the reading from the flue gas thermocouple**  **-potentiometer combination will be compared with an ASTM mercury-in-glass**  **reference thermometer at ambient conditions. If the two agree within ±1.5 pe**  **rcent (absolute), the thermocouple and potentiometer are considered to be in proper working order** 

**.** F: Dry Gas Meter and Orifice. **Two procedures will be used to calibrate the dry gas meter and orifice simultaneously. The full calibration will be**  **a complete laboratory procedure used to obtain the calibration factor of the dry gas me**  **ter. Full calibrations will be performed over a wide range of orifice settings. A s**  **impler procedure, the post test calibration, will be designed to check whether the calibra**  **tion factor has changed. HCl ICR Site-Specific Test Protocol**  **Page: 23**

**Holcim (US) Inc. Revision No: 0**  **Bloomsdale, Missouri Date: February 10, 2010** 

**A dry gas meter that is calibrated annually against a spir ometer or a set of calibrated**  **critical orifices will be used as a transfer standard. Duri ng the annual calibration,**  **triplicate calibration runs will be performed at seven flow rates ranging from 0.25 to**  **1.40 cfm.** G: Dry Gas Meter. **Each metering system receives a full calibration at the time of**  **purchase and a post-test calibration after each field use. I f the calibration factor, γ,**  **deviates by less than five percent from the initial value, the test data are acceptable.**  **If γ deviates by more than 5 percent, the meter is recalibra ted and the meter coefficient**  **(initial or recalibrated) that yields the lowest sample volum e for the test runs is used.**  **EPA Method 5 requires another full calibration anytime the post- test calibration check**  **indicates that γ changed by more than 5 percent. Standard practice is to adjust and**  **recalibrate the dry gas meter anytime γ is found to be outside the range of 0.96 to 1.04.**  **Post-test calibrations will be performed after each field test series per EPA Alt-009**  **procedures.**

H: Orifice. **An orifice calibration factor will be calculated for each flow setting during**  **a full calibration. If the range of values does not vary by more than 0.15 in H**  **2 O over**  **the range of 0.5 to 4.0 in H 2**  **O, the arithmetic average of the values obtained during the calibration is used.** 

I: Barometer. **Each field barometer will be adjusted before each test s eries to agree**  **within ±0.1 inches of a reference mercury-column barometer. The reference**  **barometer will be checked against the station pressure value ( corrected for elevation**  **difference) reported by the National Weather Service.** 6.1.3 Manual Sampling Quality Control Procedures **The following pretest QC checks will be conducted: • All sampling equipment will be thoroughly checked to ensure clea**  **n and operable components.**  **• Equipment will be inspected for possible damage from shipment. • The oil manometer or Magnehelic gauge used to measure pressure**  **across the Type S pitot tube will be leveled and zeroed.**  **• The number and location of the sampling traverse points will be checked before taking**  **measurements. • The temperature measurement system will be visually c**  **hecked for damage and operability by measuring the ambient temperature prior to each run.**  **In addition to the general QC procedures listed above, QC procedures specific to each**  **sampling method will also be incorporated into the sampling scheme. Thes e methods and specific**  **procedures are discussed below. HCl ICR Site-Specific Test Protocol**  **Page: 24**

**Holcim (US) Inc. Revision No: 0**  **Bloomsdale, Missouri Date: February 10, 2010**  **A: Sampling Train QC checks. The following QC procedures will be emphasiz ed:**  Prior to Start of Tests **• Keep all cleaned glassware and sample train components se aled until train**  **assembly. • Assemble the sampling trains in an environment free from contamination.**  **• Visually inspect each sampling train for proper assembly. • Perform pretest calculations to determine the proper sampling nozz**  **le size.**

Prior to Each Test Run **• Visually inspect the sampling nozzle. • Visually inspect the Type S pitot tube.**  **• Leak check each leg of the Type S pitot tube. • Leak check the entire sampling train.**  During Each Test Run **• Readings of temperature and differential pressure will be taken at each**  **traverse point. • All sampling data and calculations will be recorded on p**  **reformatted data sheets.**  **• All sampling data forms will be reviewed for completeness and accurac y.**  **• Any unusual occurrences will be noted during each run on the appropr iate data**  **form. • The project supervisor will review sampling data sheet**  **s daily during testing. • Properly maintain the roll and pitch axis of the Type S p**  **itot tube and the sampling nozzle.**  **• Leak check the train before and after any move from one samp ling port to**  **another during a run (at DEECO’s option) or if a filter change takes place. • Maintain the probe, filter, and impingers at the proper temperatur**  **es. • Maintain ice in the ice bath at all times.**  **• Make proper readings of the dry gas meter, delta P and delt a H, temperature,**  **and pump vacuum during sampling at each traverse point. • Maintain isokinetic sampling within ± 10% of 100%.**  After Each Test Run **• Visually inspect the sampling nozzle. • Visually inspect the Type S pitot tube.**  **• Leak check each leg of the Type S pitot tube. • Leak check the entire sampling train.**  **B: QC for Volumetric air flow rate determinations HCl ICR Site-Specific Test Protocol**  **Page: 25**

**Holcim (US) Inc. Revision No: 0**  **Bloomsdale, Missouri Date: February 10, 2010** 

Flue Gas Velocity. **Data required to determine the flue gas velocity will be col lected**  **using the methodology specified in EPA Method 2. Quality control proce dures are**  **as follows. • Visually inspect the Type S pitot tube before and after sampling.**  **• Leak check both legs of the pitot tube before and after sampling. • Check the number and location of the sampling traverse points bef**  **ore taking measurements.**  Flue Gas Molecular Weight. **Samples to be used for determination of flue gas molecular weight will be collected using the continuous sampling t**  **echnique specified in EPA Method 3A. Quality control will focus on the following procedures:**  **• The sample acquisition system will be leak checked before operation. • A constant sampling rate will be used in withdrawing a sample.**  **• The sampling port will be properly sealed to prevent air in-lea kage.** 

Moisture Content. **The moisture content of the gas stream will be determined usi ng**  **the technique specified in EPA Method 4. The following QC checks wil l be**  **performed: • The sampling train will be leak checked before and after each run.**  **• Ice will be maintained in the ice bath throughout each run. HCl ICR Site-Specific Test Protocol**  **Page: 26**

**Holcim (US) Inc. Revision No: 0**  **Bloomsdale, Missouri Date: February 10, 2010**  

### 7.0 REPORTING AND DATA REDUCTION REQUIREMENTS 7.1 Report Format

**TABLE OF CONTENTS 1.0 Introduction**  **1.1 Summary of Test Program . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . X**  **1.2 Key Personnel . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . X**  **2.0 Source and Sampling Location Descriptions 2.1 Process Description . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .**  **. . . . . . . . X 2.2 Control Equipment Description . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .**  **. . . X 2.3 Flue Gas and Process Sampling Locations . . . . . . . . . . . . . . . . . . . . . . . .**  **X 3.0 Summary and Discussion of Results**  **3.1 Objectives and Test Matrix . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . X**  **3.2 Field Test Changes and Problems . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . X**  **3.3 Summary of Results . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . X**  **4.0 Sampling and Analytical Procedures 4.1 Emission Test Methods . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .**  **. . . X 4.2 Process Test Methods . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .**  **. . . . X 5.0 QA/QC Activities . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .**  **. . . . . . . . . . . . . . X**
**APPENDICES A - Results and Calculations**  **B - Raw Field Data C - CEM Results**  **D - FTIR Results E - Equipment Calibration Data Sheets and Calibration Certificates of Ana**  **lysis F - List of Participants** **HCl ICR Site-Specific Test Protocol Page: 27** 

**Holcim (US) Inc. Revision No: 0**  **Bloomsdale, Missouri Date: February 10, 2010**  7.2 Data Reduction and Summary **An example data summary table is shown as Table 7.1.**

TABLE 7.1 EXAMPLE DATA SUMMARY TABLE FOR HYDROGEN CHLOR IDE

EMISSION TEST RESULTS, HOLCIM (US) SAINT GENEVIEVE FACILITY, BOTH RAW MILLS OFF CONDITION; FEBRUARY 15, 2010 Test Parameter Run X Run X Run X Average **Time xx:xx-xx:xx xx:xx-xx:xx xx:xx-xx:xx ----**  **Stack Gas Temperature (** E **F) xxx xxx xxx xxx Stack Gas Moisture x.x% x.x% x.x% x.x%**  **Volumetric Flowrate actual cfm**  **dry standard cfm xxx,xxx**  **xxx,xxx xxx,xxx** 

**xxx,xxx xxx,xxx** 

**xxx,xxx xxx,xxx** 

**xxx,xxx Oxygen Content x.x% x.x% x.x% x.x%**  **Hydrogen Chloride Emissions Concentration, ppm**  **by volume, wet basis Concentration, ppm**  **by volume, dry basis Concentration, ppm at 7% oxygen**  **x.xx x.xx**  **x.xx x.xx** 

**x.xx x.xx**  **x.xx**

**x.xx x.xx**  **x.xx**

**x.xx x.xx** **HCl ICR Site-Specific Test Protocol Page: 28** 

**Holcim (US) Inc. Revision No: 0**  **Bloomsdale, Missouri Date: February 10, 2010** 



### 8.0 PLANT ENTRY AND SAFETY

8.1 Safety Responsibilities **The DEECO Safety Officer (Dr. Scott Steinsberger) is resp onsible for ensuring compliance**  **with plant entry, health, and safety requirements. The Holcim Ste. Genvieve Plant Contact (James Lunan) has the authori**  **ty to impose or waive facility restrictions.**  **The DEECO Test Director (Dr. Scott Steinsberger) has authori ty to negotiate with facility**  **person any deviations from the facility restrictions.** 8.2 Safety Program **The DEECO Health and Safety Program is attched as Appendix A.** 8.3 Safety Requirements

**All test personnel will adhere to the following standard safety and precautionary measures**  **as follows:**

C **Confine selves to test area only.**

C **Wear hard hats at all times on-site, except inside sample r ecovery trailers**  **and mobile CEM laboratory.**

C **Wear protective shoes or boots in test area.**

C **Wear protective glasses or goggles at the test sites, and other areas as**  **designated.**

C **Have readily available first aid equipment and fire extinguishers. Before or on the first day on-site, the Test Director will**  **fill out the Holcim Contractor Job Safety Plan and the Pre-Shift Hazard Assessme**  **nt form and provide copies to be posted at each test site.** **HCl ICR Site-Specific Test Protocol Page: 29** 

**Holcim (US) Inc. Revision No: 0**  **Bloomsdale, Missouri Date: February 10, 2010**  

### 9.0 PERSONNEL RESPONSIBILITIES AND TEST SCHEDULE

9.1 Test Site Organization **The key tasks and task leaders are:**

C **Management:** William G. DeWeeS

C **Test Preparation/Site Restoration:** Scott C. Steinsberger

C **Modifications to Facility/Services:** James Lunan

C **Sampling Site Accessibility:** James Lunan

C **Sample Recovery:** Marc Hamilton

C **Daily Sampling Schedule:** Scott C. Steinsberger 9.2 Test Preparations **No special sampling and analytical equipment is needed. No modifi cations to the facility are**  **needed. Suitable safe access to the sampling location currently exists. Holcim will provide the**  **necessary electrical power. Sample recovery of the Method 4 tr ains will be conducted in a mobile**  **recovery laboratory already on-site.** 9.3 Test Personnel Responsibilities and Detailed Schedule **DEECO personnel will arrive at the plant about 1.5 hours before the start of the first test run**  **on each of the two days scheduled for sampling. Pre-test activities on these days wi ll include:** 

C **Meet with the plant contact to review the daily test objectives.**

C **Prepare and set-up (including leak checks) the manual method trains at all test locations.** 

C **Calibrate instrumental analyzers and verify that the data ac quisition systems are**  **functioning properly.**

C **Verify communication links between team members/leaders/plant per sonnel.** 

## Appendix A DEECO Health and Safety Plan**DEECO Inc. 3404 Lake Woodard Road**  **Raleigh, NC 27604 (919) 250-0285 (ph); (919) 250-1835 (Fax) www.stacksampling.com** 

**DEECO**
**HEALTH AND SAFETY PLAN**

**January 2010 DEECO**  Health and Safety Plan

**Section Page**  **1.0 Introduction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1**  **1.1 Responsibilities . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1**  **1.2 Employee Conduct . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2**  **1.3 Pre-Work Safety Considerations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4**  **1.4 Employee Safety Education, Training, and Evaluation . . . . . . . . . . . . . . . . . . . . . 4**  **2.0 General Safety Requirements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7**  **2.1 First Aid for Accidents and Injuries . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7**  **2.2 Audit/Inspection Procedures . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8**  **2.3 Bloodborne Pathogens . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9**  **2.4 Aerial Devices (Man Lifts) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9**  **2.5 Confined Space Entry . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11**  **2.6 Documented Safety Meetings . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11**  **2.8 Electrical - GFCI or Grounding Program . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12**  **2.9 Equipment Inspection/Maintenance . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13**  **2.10 Excavation/Trenching/Shoring . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13**  **2.11 Floor/Wall Openings . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14**  **2.12 Hearing Conservation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16**  **2.13 Housekeeping . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18**  **2.14 Manual Lifting . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 19**  **2.15 Mechanical Lifting . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 19**  **2.16 Mechanical and Electrical Safety . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 19**  **2.17 New Employee Orientation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 20**  **2.18 Power and Hand Tools . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 20**  **2.19 Process Safety Management . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 20**  **2.20 Scaffolding . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 21**  **2.21 Stairways and Ladders . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 22**  **2.22 Travel Safety . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 24**  **2.23 Thermal Stress . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 24**  **2.24 Welding and Cutting . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 26**  **2.26 Lockout/Tagout (LOTO) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 26**  **2.27 Fall Protection . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 27**  **2.28 Combustible Gas (LEL), Carbon Monoxide, Hydrogen Sulfide, and/or Ox ygen**  **Monitors . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 38**  **2.29 Emergency Response/Evacuation Program . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 41**  **2.30 Compressed Air Systems . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 42**  **2.31 Concrete Construction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 42**  **2.32 Powder-Actuated Tools . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 42** **Section Page** 

**3.0 Chemical Safety Guidelines . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 43**  **3.1 General Characteristics . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 45**  **3.2 Acids . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 47**  **3.3 Bases . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 47**  **3.4 Compressed Gases . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 48**  **3.5 Cryogenic Materials . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 50**  **3.6 Flammable Liquids and Gases . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 51**  **3.7 Organic Solvents . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 52**  **3.8 Oxidizing Agents . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 53**  **3.9 Asbestos Awareness . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 53**  **3.10 Benzene Awareness . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 54**  **3.11 Hydrogen Sulfide Awareness . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 54**  **3.12 Lead Awareness . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 56**  **4.0 Hazard Communication Requirements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 57**  **4.1 Material Safety Data Sheets . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 59**  **4.2 Chemical Labelling . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 60**  **4.3 Employee Exposure Monitoring . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 61**  **4.4 Employee Medical Surveillance . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 61**  **4.5 Employee Access to Records . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 61**  **5.0 Personal Protective Equipment . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 63**  **5.1 Respiratory Protection . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 63**  **5.2 Gloves . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 66**  **5.3 Protective Eyewear . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 66**  **5.4 Protective Clothing . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 67**  **5.5 OSHA Levels of Protection . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 68**  **5.5 Training for the Use Personal Protective Equipment . . . . . . . . . . . . . . . . . . . . . . 70** **DEECO Health and Safety Plan Page 1 January 2010**



### 1.0 Introduction **DEECO, Inc. (DEECO) is committed to the health and safety of its empl oyees. In order to ensure**  **that all tasks are performed safely, this Health and Safety Plan (HSP) has been prepared. The**  **procedures detailed in this HSP outline individual responsibilities, specific operating procedures,**  **training requirements, and specific information on potential safety and health ha zards.**  **The hazards faced by DEECO field personnel are varied, and speci fic controls of many hazards are**  **the responsibility of the client. This HSP will enable employees to rec ognize potential hazards so**  **that the client may take actions to correct the condition before t he work is performed. This HSP also**  **identifies DEECO activities which may pose significant health and safet y risks.**  1.1 Responsibilities **This section details the responsibilities for employees and ma nagement in the implementation of the**  **HSP.**

President **The President of DEECO has overall responsibility for compliance with all applicable federal and**  **state regulations and the provisions of this HSP. Periodic meeting s with managers and employees**  **should be conducted to discuss:**

# **The importance of health and safety.** # **Changes in regulations regarding health and safety.** # **Recent employee monitoring results.** # **Any recent employee accidents/injuries and possible preventive measures to avoid**  **a recurrence. In addition to the above responsibilities, the President is responsi**  **ble for authorizing any deviations from the HSP.**  Managers **Project managers and field team leaders are responsible fo r the health and safety of all persons**  **assigned to the specific project. Project managers and field team lea ders must ensure that:**  # **Employees are properly trained to perform all tasks in a safe manner.** # **Proper personal protective equipment are available and in good wor king condition.**  # **Persons using personal protective equipment have been instructed on their use.** # **Emergency equipment is available and in good working condition.** # **Employees are informed of any exposure monitoring performed in thei r work area**  **that may be representative of their chemical exposure.** # **All safety considerations have been discussed with the client prior to mobil ization.**  # **All aspects of the projects have been discussed and are underst ood with the team**  **leader and team members.** # **All appropriate safety equipment is available and in good working condition prior to**  **mobilization.** # **All records (employee training, respirator fit-testing, etc .) are present for all team** **DEECO Health and Safety Plan Page 2 January 2010 members.**  # **Copies of MSDSs for all chemicals used by DEECO are available for the c lient.**  # **All tasks are performed in a safe manner.** # **All accidents, injuries, or spills are reported immediately.** # **Any unsafe condition is reported immediately.** # **They cooperate with any monitoring surveys.** DEECO Safety Officer **The DEECO Safety Officer (SO) is responsible for the revi ew and maintenance of the Health &**  **Safety Plan. In addition, the SO is responsible for:** # **Identifying when employee exposure monitoring is necessary.** # **Writing exposure reports and reporting results to the appropria te department manager**  **and employees.** # **Ensuring that appropriate employee training is provided.** # **Investigating reported accidents with department managers.** # **Ensuring that new information on health, safety, employee training, or changes in**  **legal requirements are conveyed to the Director of Field Services.** 1.2 Employee Conduct **Appropriate employee conduct is essential in conveying a profess ional image to DEECO clients.**  **When performing work on client premises:** # **Dress professionally.** # **Contact the team leader if problems with a client arises.** # **Discuss disagreements with other DEECO personnel in private, not in front of the**  **client.** # **Do not discuss DEECO company policies or practices with client s (e.g. management,**  **compensation. etc.)** # **Direct all questions regarding sampling or project activities to the te am leader.**  # **Do not convey DEECO in a negative manner to clients. Any disagree ments with**  **company practices should be discussed directly with your manager.** # **Do not volunteer data to client employees.** # **Release data only to the designated client contact.** # **Do not promise a date for the final report. Have the client c ontact the project**  **manager or coordinator for a final report date.** # **Remain busy while on the client's premises.** # **Remain within designated areas of plant site.** # **Notify team leader when leaving area.** # **Notify client when leaving site for lunch or the end of the day.** # **Be on time for client meetings. If problems arise, call the client im mediately if the**  **scheduled time cannot be kept.** # **Follow all rules and regulations of the client while on the plant site.** # **If approached by the news media, do not offer any information. Refer all questions**  **to the client. DEECO Health and Safety Plan Page 3 January 2010** 

Drugs and Alcohol Use **It is DEECO's desire to provide a drug-free, healthful, and safe workplace. To promote this goal,**  **employees are required to report to work in appropriate mental and physical condition to perform**  **their jobs in a satisfactory manner. While on DEECO premises and while conducting business-related act**  **ivities off DEECO premises, no employee may use, possess, distribute, sell, or be under the infl**  **uence of alcohol or engage in the unlawful manufacture, distribution, dispensation, possession, or use of ill**  **egal drugs. Violations of this policy may lead to disciplinary action, up to and including i**  **mmediate termination of employment, and/or required participation in a substance abuse re**  **habilitation or treatment program. Such violations may also have legal consequences.**  **The legal use of prescribed drugs is permitted on the job only if it does not impair an employee's**  **ability to perform the essential functions of the job effecti vely and in a safe manner that does not**  **endanger other individuals in the workplace. To inform employees about important provisions of this policy, DEEC**  **O has established a drug-free awareness program. The program provides information on the dangers**  **and effects of substance abuse in the workplace, resources available to employees, and cons**  **equences for violations of this policy.**  **Employees with questions or concerns about substance dependency or ab use are encouraged to**  **discuss these matters with their supervisor or the Personnel Di rector to receive assistance or referrals**  **to appropriate resources in the community. Employees with drug or alcohol problems that have not resulted in, a**  **nd are not the immediate subject of, disciplinary action may request approval to take unpai**  **d time off to participate in a rehabilitation or treatment program through DEECO's health insur**  **ance benefit coverage. Leave may be granted if the employee agrees to abstain from use of the**  **problem substance; abides by all DEECO policies, rules, and prohibitions relating to conduct in the wor**  **kplace; and if granting the leave will not cause DEECO any undue hardship.**  **Under the Drug-Free Workplace Act, an employee who performs work f or a government contract**  **or grant must notify DEECO of a criminal conviction for drug- related activity occurring in the**  **workplace. The report must be made within five days of the conviction. Employees with questions on this policy or issues related to drug or**  **alcohol use in the workplace should raise their concerns with their supervisor or the Personnel D**  **irector without fear of reprisal.**

Abusive Language **Abusive or vulgar language, ethnic or sexual slurs and insults will not be tolerated on client or**  **DEECO premises. Use of such language is not only offensive, but may be seen as illegal**  **harassment. Inappropriate language or insults can result in imm ediate, appropriate action upon the**  **employee by DEECO. If problems with employee use of such l anguage occurs, notify your manager.** **DEECO Health and Safety Plan Page 4 January 2010**

1.3 Pre-Work Safety Considerations **The Project Coordinator or Manager should determine through a site visit, or through extensive**  **conversations with the client, if any unusual safety hazards exist at the work site. Additional**  **equipment, if needed, should be determined by the Project Coordinator/Ma nager and the DEECO**  **S.O.** 1.4 Employee Safety Education, Training, and Evaluation **All DEECO personnel shall initially receive the equivalent of t he OSHA 40-hour Training for**  **Hazardous Waste Operators. The 8-hour Refresher Training shall b e completed annually by all**  **personnel. Additional training and education may be required for specific jo**  **b responsibilities. The training requirements for additional education shall be set by the President.**  Employee Safety Evaluation Program **An annual evaluation of each employee’s safety performance will be conducted. Evaluating an employee’s safety performance involves measuring t**  **he level at which employees are achieving both their own personal safety goals and the company’s ex**  **pected safety performance standards. Integrating health and safety into a performance apprai**  **sal system provides management with a unique opportunity to tie the employee’s accountabilities a**  **nd achievements to the company’s objectives and strategic plans.**  **The goals of the Employee Safety Evaluation Program are; 1. Communicating information to employees on how well they are mee**  **ting the health and safety performance expectations of their jobs;**  **2. Identifying areas for coaching to help employees improve their health and safety performance**  **and develop safe work practices; 3. Providing opportunities to further communicate the organization’s**  **health and safety performance expectations;**  **4. Supporting the organizational succession plan; 5. Providing feedback to the organization about its recruitment and s**  **election process as well as its integrated health and safety training/development program;**  **6. Providing feedback about the employee’s perceptions of the compa ny’s health and safety**  **performance and standards. For employees, meeting the health and safety expectations of a job requires**  **them to: 1. Report hazards or hazardous conditions to their supervisor;** **DEECO Health and Safety Plan Page 5 January 2010**

**2. Work in a safe manner at all times by using appropriate pr otective gear and controls on**  **equipment; 3. Follow company policies and procedures;**  **4. Wear personal protective equipment as instructed; 5. Participate in health and safety initiatives (e.g. ergonomic a**  **ssessment, hygiene testing etc.) For supervisors, meeting the health and safety expectations of a job require**  **s the ability to: 1. Coach employees on safe work practices;**  **2. Enforce company policies and procedures; 3. Act as a positive role model for staff with respect to safe work practi**  **ces; 4. Support any staff who are members of the joint health and safety committee;**  **5. Be aware of their legal requirements under the Occupational Health and Safe ty Act;**  **6. Review new jobs/tasks/processes/equipment for safety concerns; 7. Follow-up on reported concerns in a timely fashion;**  **8. Encourage employee input into safety-related concerns and solution- finding processes; and**  **9. Discipline staff when required for failure to follow safety procedures. The Employee Safety Evaluation Program will quantify the health**  **and safety areas being monitored and provide qualitative feedback on employee health and safety performance.**  **The Employee Safety Evaluation Program will evaluate a employ ee’s performance on the following;**  **1. Reporting hazards or hazardous conditions to their supervisor; 2. Working in a safe manner at all times by using appropriate protecti**  **ve gear and controls on equipment;**  **3. Following company policies and procedures; 4. Wearing personal protective equipment as instructed;**  **5. Participating in health and safety initiatives (e.g. ergonomic assessment, hygiene testing etc.)**  **The Employee Safety Evaluation Program will evaluate a supervisor’s performance on the following;** **DEECO Health and Safety Plan Page 6 January 2010**

**1. Effectiveness in managing health and safety issues in their de partment or area of**  **responsibility; and 2. Establishing specific criteria for minimum health and safety standards** 

**. DEECO Health and Safety Plan Page 7 January 2010** 



### 2.0 General Safety Requirements **The procedures and guidelines detailed in the following sections are to be used by DEECO Field**  **personnel while performing work on either DEECO or client premis es. If the client has additional**  **safety procedures, field personnel are to follow the procedures whi ch are more stringent. In all cases,**  **all OSHA, MSHA and/or EPA requirements shall be met.** 2.1 First Aid for Accidents and Injuries **In the absence of an infirmary, clinic, hospital, or physician, that is reas onably accessible in terms**  **of time and distance to the worksite, which is available for the t reatment of injured employees, a**  **person who has a valid certificate in first-aid training from t he U.S. Bureau of Mines, the American**  **Red Cross, or equivalent training that can be verified by documentary evidence, s hall be available**  **at the worksite to render first aid. First aid supplies shall be easily accessible when require**  **d. The contents of the first aid kit shall be placed in a weatherproof container with individual sealed packages**  **for each type of item, and shall be checked by the employer before being sent out on each job a**  **nd at least weekly on each job to ensure that the expended items are replaced.**  **Proper equipment for prompt transportation of the injured pers on to a physician or hospital, or a**  **communication system for contacting necessary ambulance service, shall be provided.**  **In areas where 911 is not available, the telephone numbers of the phy sicians, hospitals, or**  **ambulances shall be conspicuously posted. Where the eyes or body of any person may be exposed to injurious c**  **orrosive materials, suitable facilities for quick drenching or flushing of the eyes and body (e.g. safety showers a**  **nd emergency eyewash systems) shall be provided within the work area for im**  **mediate emergency use. The location of these facilities for quick drenching or flushing of the eyes**  **and body shall be identified and all employees in the affected area will be shown the location of these faci**  **lities. The reporting of any work-related accident, illness, or injury is**  **required by Worker's Compensation regulations. North Carolina law requires that a manager's repor**  **t on an accident or injury be filed within 10 days after the incident.**  **The reporting of incidents will enable employees and management to determine what possible**  **corrective actions can be taken to avoid a recurrence of the incident. Responsibilities**  **Project managers or coordinators must ensure that:** # **Immediate care is obtained for all accidents or injuries.** # **All employee accidents or injuries are recorded on the DEECO A ccident Report form**  **by the employee.** # **Copies of the Accident Report form are sent to the Personnel Director and the**  **DEECO S.O. DEECO Health and Safety Plan Page 8 January 2010** 

# **Accident reports are reviewed with the employee and possible p reventive measures**  **are noted and implemented if required.** # **Any equipment involved in an incident is removed from service until re paired or**  **replaced. The Personnel Director must ensure that:**  # **Necessary North Carolina forms are completed, distributed, and ma intained for any**  **occupational injury or accident.** # **The OSHA Form 300 is updated and posted on the bulletin board in the Br eak Room.**  **Employees must ensure that:** # **All accidents or injuries are reported immediately to the D epartment Manager,**  **Project Manager, or Project Coordinator.** # **All details of the accident or injury are recorded on the DEECO Accident Report**  **form.** 2.2 Audit/Inspection Procedures **Safety audits and inspections of all work areas will be conducted periodically by the Safety Officer**  **or a representative thereof. Procedures for conducting an inspection of a job site will be as follows.**  **The following items, while not inclusive, are indicators of some of t he areas of concern for good job**  **site safety covered in a routine inspection or audit. Item**  **Acceptable Not Acceptable**  **NA Employee Safety Training ( ) ( ) ( )**  **Safety Manual On site ( ) ( ) ( ) Assigned Responsibilities ( ) ( ) ( )**  **Confined Space Entry ( ) ( ) ( ) Fire Protection ( ) ( ) ( )**  **Electrical - GFCI or Grounding Program ( ) ( ) ( ) Equipment Inspection/Maintenance ( ) ( ) ( )**  **Excavation/Trenching/Shoring ( ) ( ) ( ) Floor/Wall openings ( ) ( ) ( )**  **Hearing Conservation ( ) ( ) ( ) Housekeeping ( ) ( ) ( )**  **Mechanical Lifting ( ) ( ) ( ) Mechanical and Electrical Safety ( ) ( ) ( )**  **Power Tools ( ) ( ) ( )**  **Scaffolding ( ) ( ) ( )**  **Stairways and Ladders ( ) ( ) ( ) Travel Safety Followed ( ) ( ) ( )**  **Thermal Stress ( ) ( ) ( ) Chemical Safety Guidelines Met ( ) ( ) ( )**  **Hazard Communication Requirements Met ( ) ( ) ( ) Material Safety Data Sheets On site ( ) ( ) ( )**  **Chemical Labelling Clear and correct ( ) ( ) ( ) Personal Protective Equipment ( ) ( ) ( )** **DEECO Health and Safety Plan Page 9 January 2010**

**Respiratory Protection ( ) ( ) ( ) Gloves**  **( ) ( ) ( ) Protective Eyewear ( ) ( ) ( )**  **Protective Clothing ( ) ( ) ( ) Fall Protection ( ) ( ) ( )**  2.3 Bloodborne Pathogens **In the normal course of work, it is not reasonably anticipated that DEECO employees will encounter**  **occupational exposure of the skin, eye, mucous membrane, or parentera l contact with blood or other**  **potentially infectious materials. Consequently, DEECO is not requi red to have a written Exposure**  **Control Plan. However, in the case of an accident, all contact with blood or blood pr**  **oducts should be avoided to prevent the risk of exposure to bloodborne pathogens, . Cuts, scrap**  **es, and abrasions should be reported to the safety officer or appointed representative and pr**  **oper health care should be provided by trained personnel. Rubber gloves should be worn at all times w**  **hen treating injuries causing risk to bloodborne pathogens.**  **Rubber gloves, protective resuscitation masks, and other first aid items are contained in the field first**  **aid kit which is to be present on each project.** 2.4 Aerial Devices (Man Lifts) **On occasions, DEECO employees may be required to use aerial devices (man lifts) to access**  **sampling locations. The following are examples of aerial devices; 1. An aerial device is any vehicle-mounted device, telescoping or ar**  **ticulating, or both, which is used to position personnel;**  **2. An aerial ladder is an aerial device consisting of a single - or multiple-section extensible**  **ladder; 3. An articulating boom platform is an aerial device with two or**  **more hinged boom sections.; 4. An extensible boom platform is an aerial device (except la**  **dders) with a telescopic or extensible boom. Telescopic derricks with personnel platform a**  **ttachments shall be considered to be extensible boom platforms when used with a personnel plat**  **form; 5. An insulated aerial device is an aerial device designed for wor**  **k on energized lines and apparatus;**  **5. A mobile unit is a combination of an aerial device, its vehicle, and related equipm ent;**  **6. A platform is any personnel-carrying device (basket or bucket) which is a component of an**  **aerial device; 7. A vehicle is any carrier that is not manually propelled; and** **DEECO Health and Safety Plan Page 10 January 2010**

**8. A vertical tower is an aerial device designed to elevate a p latform in a substantially vertical**  **axis.** Specifc Requirements for Aerial Lifts **Only trained persons shall operate an aerial lift. For ladder trucks and tower trucks, before the truck is moved for highwa**  **y travel, aerial ladders will be secured in the lower traveling position by the locking device ab**  **ove the truck cab, and the manually operated device at the base of the ladder, or by other e**  **qually effective means (e.g., cradles which prevent rotation of the ladder in combination with positive acting linear ac**  **tuators). For extensible and articulating boom platforms, the lift controls**  **shall be tested each day prior to use to determine that such controls are in safe working condition.**  **Belting off to an adjacent pole, structure, or equipment while worki ng from an aerial lift shall not**  **be permitted. Employees shall always stand firmly on the floor of the basket,**  **and shall not sit or climb on the edge of the basket or use planks, ladders, or other devices for a work position.**  **A body belt shall be worn and a lanyard attached to the boom or bas ket when working from an aerial**  **lift. Boom and basket load limits specified by the manufacturer shall not be exce**  **eded. The brakes shall be set and outriggers, when used, shall be positi**  **oned on pads or a solid surface. Wheel chocks shall be installed before using an aerial lift on an incline.**  **An aerial lift truck may not be moved when the boom is elevated in a working position with men in**  **the basket, except for equipment which is specifically desig ned for this type of operation in**  **accordance with the provisions of OSHA 1910.67, paragraphs (b)(1) and (b)(2). Articulating boom and extensible boom platforms, primarily desi**  **gned as personnel carriers, shall have both platform (upper) and lower controls. Upper controls shall**  **be in or beside the platform within easy reach of the operator. Lower controls shall provide for**  **overriding the upper controls. Controls shall be plainly marked as to their function. Lower level**  **controls shall not be operated unless permission has been obtained from the employee in the lift, except i**  **n case of emergency. Climbers shall not be worn while performing work from an aerial lift.**  **The insulated portion of an aerial lift shall not be altered i n any manner that might reduce its**  **insulating value. Before moving an aerial lift for travel, the boom(s) shall be i**  **nspected to see that it is properly cradled and outriggers are in stowed position, except as provided in OSHA 1910.67,**  **paragraph (c)(2)(viii). DEECO Health and Safety Plan Page 11 January 2010** 

2.5 Confined Space Entry **A Confined Space in an enclosure having limited access and egress. Examples of confined spaces**  **include, but are not limited to:** # **Storage tanks, tank cars, process vessels, bins, silos, boiler s, and other tank-like**  **compartments usually with only a manhole for entry.** # **Open-topped spaces of more than 4 feet in depth, such as pits, vault s and vessels, not**  **subject to good natural ventilation.** # **Septic tanks, sewers, underground utility tunnels, pipelines, and similar struct ures.**  **Confined spaces may contain atmospheres that are hazardous to lif e and health because of the**  **presence of flammable, explosive, or toxic contaminants or becaus e of either a deficiency or excess**  **of oxygen. It is DEECO policy not to permit employees to ente r a confined space. In the event that**  **confined space entry is necessary as part of a project, the client is to provide DEECO personnel with**  **training, life-support equipment, and emergency/rescue personnel duri ng any confined space work.**  2.6 Documented Safety Meetings **Safety Meetings will be held on the first day of a project, on-site. A review of safety conditions will**  **be made by the project manager/field team leader at the end of each day's work. Any unusual or**  **notable health or safety concerns will be noted in the field log, and discussed with all field team**  **members. All field safety meetings will be documented in the field log book, and a copy of the**  **appropriate pages will be included in the final written report to the cli ent.**  **The President shall ensure that meetings are held periodically to address safety violations,**  **procedures, and/or updates. The dates, attendees, and topics of these meetings will be documented**  **and placed in the Safety Meetings file.**

2.7 Fire Protection **Every employee should be aware of the combustible characterist ics of the chemicals and materials**  **they use or may come in contact with. This information can be found on the chemical's Material**  **Safety Data Sheet (MSDS), or labels on the material container. When performing work on a client's site, the Project Manager or Coordinator must:**  # **Be able to clearly identify all regular and emergency ex its in the building or work**  **area.** # **Receive a site evacuation route from the client.** # **Receive emergency notification procedures from the client (e .g. number to call in**  **case of fire, explosion, etc.).** # **Ensure all team members are aware of the above information. Care should be taken when storing or using chemicals or hazardous materials in DE**  **ECO vehicles or mobile laboratories. All vehicles and mobile laboratories are equipped w**  **ith fire extinguisher. If a fire should occur:**  # **Aim fire extinguisher at the base of the fire.** # **Never allow the fire to come between you and an exit.** # **Never use water on electrical or burning liquid fires. If the fire is too large to be contained with one fire extinguisher:** **DEECO Health and Safety Plan Page 12 January 2010**

# **Immediately notify the site emergency contact. Report locat ion of fire, material**  **burning, and if any injuries are involved.** # **Evacuate the area.** Fire Extinguisher Classes
Class A **- for use on ordinary combustible materials such as paper, wood, etc.** Class B **- for use on flammable and combustible liquids, greases, paints, etc.** Class C **- for use on electrical fires.** Class D **- for use on combustible metals. All fire extinguishers located in the DEECO vehicles and mobil**  **e laboratories are rated for Class A, B, and C fires.**  2.8 Electrical - GFCI or Grounding Program **It is the policy of DEECO to establish and implement an assur ed equipment grounding conductor**  **program on work sites covering all cord sets, receptacles whic h are not a part of the permanent**  **wiring of the building or structure, and equipment connected by cord and p lug which are available**  **for use or used by employees. This policy shall apply to all w ork sites not equipped with ground**  **fault circuit interrupters in accordance with OSHA standard 1926.400 (h). The project manager/field team leader shall implement the**  **assured equipment grounding conductor program where existing and predictable hazards are identifyedi**  **the surrounding area or working conditions which are unsanitary, hazardous or dangerous to employees, and**  **who is authorized to take prompt corrective measures to eliminate them.**  **The project manager/field team leader shall be responsible and account able for the following:**  **Each cord set, attachment cap, plug and receptacle of cord set a nd any equipment connected by cord**  **and plug, except cord sets and receptacles which are fixed and not exposed to damage, shall be**  **visually inspected before each day's use for external defects, such as def ormed or missing pins, or**  **insulation damage, and for indication of possible internal damage . Equipment found damaged or**  **defective may not be used until repaired. The project manager/field team leader is responsible for t**  **ests on all cord sets, receptacles which are not a part of the permanent wiring of the building or structure, a**  **nd cord and plug connected equipment repaired to be grounded. Tests shall be documented on the**  **log for assured equipment grounding conductor program and shall be on the job site for inspection**  **by OSHA officials and any affected employee. Equipment that does not meet prescribed tes**  **t shall not be put into service. The following tests shall be performed:**  **1. All equipment grounding conductors shall be tested for continuity and shall be ele ctrically**  **continuous. DEECO Health and Safety Plan Page 13 January 2010** 

**2. Each receptacle and attachment cap or plug shall be tested for correct attachment of the**  **equipment grounding conductor. The equipment grounding shall be connected to it s**  **terminal.. In accordance with OSHA Construction Safety and health Standards 1926.21 Safety**  **Training and Education, project manager/field team leader shall attend such**  **training sessions as the company may deem necessary.**  **A copy of this policy shall be at the job site for inspec tion and copy by OSHA officials and any**  **affected employee. Management retains the authority to designa te that certain jobs comply with**  **regulation 1926.400 (h) by use of ground fault circuit interrupters in li eu of the program established**  **above. A copy of the completed forms will be kept on each appli cable job site for inspection**  **purposes. Electric power operated tools and power cords shall be UL appr**  **oved, double insulated or have the third wire ground whole and in place. All 120-volt single phase, 15- and 20**  **-ampere receptacle outlets on construction sites, which are not a part of the permanent**  **wiring of the building or structure and which are in use by employees, shall have approved ground-fault cir**  **cuit interrupters (GFCI) for personnel protection.**  **All equipment and power cords are to be inspected prior to the fi eld project. Any equipment or**  **power cord which is not in proper working order shall be tagged as "D AMAGED-DO NOT USE"**  **and returned to the DEECO laboratory for repair or replacement.** 2.9 Equipment Inspection/Maintenance **Mechanical and electrical equipment will be periodically insp ected according to the manufacturers**  **instructions to ensure they are in proper working order, all cords and parts are not chipped, frayed**  **or broken, and recommended maintenance procedures are conducted on schedule. E quipment that**  **does not meet safety standards will be repaired or replaced before use.** 2.10 Excavation/Trenching/Shoring **DEECO personnel shall not perform excavation or trenching work, nor sha ll DEECO personnel be**  **expected to enter an excavation or trench. Should such entry be requir ed on a project, the client must**  **ensure: - Underground lines, equipment and electrical cables shall be located, identif**  **ied and de-energized prior to beginning work.**  **- Walls and faces of trenches and excavations, four or more feet de ep, are shored,**  **sloped or shielded as dictated by the type of soil encountered. - Daily inspections are conducted by a competent person for evidenc**  **e of a situation that could result in possible cave-ins, indications of failure of pr**  **otective systems or other hazardous conditions.**  **- Employees are not be permitted underneath loads handled by lifting or digging**  **equipment. Employees shall be required to stand away from any vehi cle being**  **loaded or unloaded. DEECO Health and Safety Plan Page 14 January 2010** 

**- Employees are be protected from excavated or other material s and equipment that**  **could pose a hazard by falling or rolling in excavations. - Physical barriers are be placed around or over trenches and ex**  **cavations. Barriers**

**shall be removed only when necessary to provide access to personnel or equipment.**  **Flashing light barricades shall be provided at night. - A stairway, ladder, ramp or other safe means of egress**  **is located in trench excavations that are four feet or more in depth so as to require no**  **more than 25 feet of lateral travel for employees.**  **- Backfilling and removal of support systems are performed only a fter employees have**  **cleared the area. All excavations shall be backfilled and graded promptl y.**  **- Trenches greater than four feet deep shall require an approved conf ined space entry**  **permit. The client requiring DEECO personnel to enter a trench or exc**  **avation shall provide training to DEECO personnel in accordance to client and OSHA regulations and policies.**  2.11 Floor/Wall Openings **With regards to guarding floor and wall openings and holes, workers wi ll comply with 29 CFR**  **1910.23 and 1926, Subpart M. General requirements are as follows:**  **1. Ladderway floor openings shall be guarded by a standard railing and toe-boards or cover.**  **In general, the railing shall be provided on all exposed sides, exc ept at entrances to stairways.**  **2. Hatchways and chute floor openings shall be guarded by one of the following: a. Hinged covers and a standard railing with only exposed side.**  **b. A removable standard railing with toe-board on not more than two sides and fixed**  **standard railings with toe boards on all other exposed sides. 3. Temporary floor openings, into which persons can accidentally wal**  **k, shall be guarded by either a standard railing with toe-board on all exposed sides, or a**  **floor hole cover that is secured against accidental displacement.**  **4. Wall openings, from which there is a drop of more than four feet , and the bottom of the**  **opening is less than three feet above the working surface, shall be guarded as fol lows:**  **a. A standard rail, if that will effectively reduce the danger of falling. If the bottom of**  **a wall opening is less than four inches above the working surface, a toe-board or an**  **enclosing screen shall also be provided. 5. Every open-sided floor or platform four feet or more above adjac**  **ent floor or ground level shall be guarded by a standard railing or equivalent. A toe-board s**  **hall be provided wherever, beneath the open sides, persons can pass or there is moving machine**  **ry or there is equipment with which falling material could create a hazard.** **DEECO Health and Safety Plan Page 15 January 2010**

**Standard Specifications 1. A standard railing shall consist of top rail, intermediate rail, toe-boa**  **rd and posts, and shall have a vertical height of approximately 42 inches.**  **a. The intermediate rail shall be halfway between the top r ail and the floor, platform**  **runway or ramp. b. Posts shall be spaced not more than eight feet on corners.**  **c. A completed railing structure shall be capable of withsta nding a load of at least 200**  **pounds applied in any direction at any point on the top rail, wit h a minimum of**  **deflection. 2. A standard handrail shall be of a construction similar to a st**  **andard rail except that it is mounted on a wall or partition and does not include an intermediate rail.**  **a. The height to handrails shall not be more than 34 inches or less tha n 30 inches from**  **top surface to tread or ramp. b. Handrails and railings shall be provided with a clearance of a**  **pproximately three inches between the rail and any other object.**  **3. Floor opening covers shall be of any material that meets the following strength requirements:**  **a. The cover, when located in roadways or vehicular aisles, shall be designed to c arry**  **a truck rear axle load of at least two times the maximum intended load. b. The floor opening cover shall be capable of supporting the max**  **imum intended load and so installed as to prevent accidental displacement.**  **4. Wall opening protection shall meet the following requirements: a. Barriers shall be of such construction and mounting that, when in pla**  **ce, they are capable of withstanding a load of at least 200 pounds applied in any di**  **rection (except upward) with a minimum deflection.**  **5. During the performance of work on low pitched roofs, employees shall be protected at all**  **open sides and edges by the use of a motion-stopping safety system. Barricades**  **1. Signs, signals and barricades shall be posted to detour passage of persons and vehicles at**  **locations where potential hazards exist. a. Barricades must be 42 inches high.**  **b. Barricades should be kept four feet back from the edge of ex cavations, holes, and**  **platforms and six feet back from the edge of low-pitched roofs. c. Barricades with flashing lights shall be provided at night.** **DEECO Health and Safety Plan Page 16 January 2010**

**2. All employees engaged in built-up roofing work will undergo traini ng so that they are able**  **to recognize and deal with the hazards of falling associated the w orking near a roof**  **perimeter.** 2.12 Hearing Conservation **DEECO personnel may be exposed to excessive noise levels while on a client's premises. The**  **project manager/field team leader will ensure all high noise areas have been identified, and that each**  **member of the field team is aware of the location of these ar eas. Hearing protection is to be provided**  **by DEECO to field personnel at no cost. Employees will wear hearing protection as instructed and**  **in all areas required.** Hearing Conservation Training Program **DEECO will train each employee who is exposed to noise at or a bove an 8-hour time weighted**  **average of 85 decibels. DEECO will institute a training progr am and ensure employee participation**  **in the program. The training program will be repeated annually for each empl**  **oyee included in the hearing conservation program. Information provided in the training program will**  **be updated to be consistent with changes in protective equipment and work processes.**  **DEECO will ensure that each employee is informed of the effec ts of noise on hearing, the purpose**  **of hearing protectors, the advantages, disadvantages, and attenuation of various types, and**  **instructions on selection, fitting, use, and care, and the purpose of audiom etric testing and an**  **explanation of the audiometric test procedures. DEECO will provide annual audiometric exams for all personnel. T**  **he President is responsible for ensuring compliance with applicable regulations (29 CFR 1910.95, "O**  **ccupational Noise Exposure", and 1926.101, "Hearing Protection").**  Audiometric Testing Program **DEECO will establish and maintain an audiometric testing progr am by making audiometric testing**  **available to all employees whose exposures equal or exceed an 8- hour time-weighted average of 85**  **decibels. The program shall be provided at no cost to employees. Audiometric tests will be be performed by a licensed or ce**  **rtified audiologist, otolaryngologist, or other physician, or by a technician who is certified by the Council**  **of Accreditation in Occupational Hearing Conservation, or who has satisfactorily demonstrated compet**  **ence in administering audiometric examinations, obtaining valid audiograms, and properly u**  **sing, maintaining and checking calibration and proper functioning of the audiometers be**  **ing used. A technician who operates microprocessor audiometers does not need to be certifi**  **ed. A technician who performs audiometric tests must be responsible to an audiologist, otolaryngologist or p**  **hysician. All audiograms obtained pursuant to this section shall meet the r**  **equirements of OSHA 1910, Appendix C: "Audiometric Measuring Instruments."** **DEECO Health and Safety Plan Page 17 January 2010**

Baseline Audiogram **Within 6 months of an employee's first exposure at or above the ac tion level, DEECO will establish**  **a valid baseline audiogram against which subsequent audiograms can be compar ed.**  **Where baseline audiograms are obtained more than 6 months after t he employee's first exposure at**  **or above the action level, employees shall wear hearing prote ctors for any period exceeding six**  **months after first exposure until the baseline audiogram is obtained. Testing to establish a baseline audiogram shall be preceded**  **by at least 14 hours without exposure to workplace noise. Hearing protectors may be used as a subst**  **itute for the requirement that baseline audiograms be preceded by 14 hours without exposure to workplace noi**  **se. DEECO will notify employees of the need to avoid high levels of non-occupational noise exp**  **osure during the 14-hour period immediately preceding the audiometric examination.**  Annual Audiogram **At least annually after obtaining the baseline audiogram, DEEC O will obtain a new audiogram for**  **each employee exposed at or above an 8-hour time-weighted average of 85 decibels.** Evaluation of Audiogram **Each employee's annual audiogram will be compared to that empl oyee's baseline audiogram to**  **determine if the audiogram is valid and if a standard threshold shift (as defined in OSHA**  **1910.95(g)(10)) has occurred. This comparison may be done by a technician. If the annual audiogram shows that an employee has suffered a standa**  **rd threshold shift, DEECO will obtain a retest within 30 days and consider the results of the retest as the annual audi**  **ogram. An audiologist, an otolaryngologist, or a physician will review prob**  **lem audiograms and will determine whether there is a need for further evaluation. DEECO**  **will provide to the person performing this evaluation, a copy of the requirements for hearing**  **conservation as set forth in OSHA 1910.95 paragraphs (c) through (n), the baseline audiogram and most rece**  **nt audiogram of the employee to be evaluated, measurements of background sound pressure le**  **vels in the audiometric test room as required in OSHA 1910Appendix D: Audiometric Test Rooms, and rec**  **ords of audiometer calibrations required by OSHA 1910 paragraph (h)(5).**  Follow-up Procedures **If a comparison of the annual audiogram to the baseline audiogram i ndicates a standard threshold**  **shift, the employee will be informed of this fact in writing, within 21 days of the de termination.**  **Unless a physician determines that the standard threshold shift is not work related or aggravated by**  **occupational noise exposure, DEECO will ensure that the employees not us ing hearing protectors**  **will be fitted with hearing protectors, trained in their use a nd care, and required to use them.**  **Employees already using hearing protectors shall be refitted and retrained in the use of hearing**  **protectors and provided with hearing protectors offering greater attenuati on if necessary.** **DEECO Health and Safety Plan Page 18 January 2010**

**The employee will be referred for a clinical audiological eva luation or an otological examination,**  **as appropriate, if additional testing is necessary or if DEEC O suspects that a medical pathology of**  **the ear is caused or aggravated by the wearing of hearing protectors. The employee will be informed of the need for an otological exami**  **nation if a medical pathology of the ear that is unrelated to the use of hearing protectors is suspected.**  **If subsequent audiometric testing of an employee whose exposu re to noise is less than an 8-hour**  **TWA of 90 decibels indicates that a standard threshold shift is not p ersistent, DEECO will inform**  **the employee of the new audiometric interpretation and mMay disc ontinue the required use of**  **hearing protectors for that employee.**

Revised Baseline **An annual audiogram may be substituted for the baseline audiogram when, in the judg ment of the**  **audiologist, otolaryngologist or physician who is evaluating the audiog ram, that the standard**  **threshold shift revealed by the audiogram is persistent or the hea ring threshold shown in the annual**  **audiogram indicates significant improvement over the baseline audiogram.** 2.13 Housekeeping **Employees shall maintain a high standard of housekeeping on the job a t all times as an integral part**  **of the work The purpose of this requirement is to ensure the safet y of all personnel entering the lob**  **location and to maintain a condition of housekeeping that is consistent wi th the desired appearance**  **of a DEECO job location. Project managers/field team leaders shall clean up work ar**  **eas daily, store all equipment and construction materials in an orderly manner in storage areas. Ba**  **rricades shall be used for temporary storage of equipment and construction materials. All scrap construction mat**  **erials and waste shall be picked up and disposed of at least daily. All location procedur**  **es for waste disposal shall be followed. Form wood and other lumber shall be neatly stored when not**  **in use. All nails shall be removed or bent over to prevent puncture wounds.**  **All stairways, walkways, ladder cages and scaffolds shall be kept clear of all cords, cables, hosed,**  **materials and anything else that might hinder personnel access. Cords, cables and hosed at stairways,**  **walkways and scaffolds will be supported at least seven fee t overhead or laid flat outside of**  **walkways. All spills of oil, solvents, chemicals and any regulated liquids sh**  **all be reported to the site representative immediately and shall be properly cleaned up**  **and disposed of. Dumping of these materials in floor drains, sanitary sewers, storm sewers. drai**  **nage ditches, or other open ground is forbidden.**  **Employees shall be responsible for keeping all location roads f ree from all debris resulting from their**  **performance of the work. Storage of combustible and flammable m aterials shall not be located under**  **overhead pipelines and utilities. Loose materials on roofs or other overhead structures shall be**  **removed or secured to prevent being blown or bumped off. Accumulation of materials that may** **DEECO Health and Safety Plan Page 19 January 2010**

**create a fire hazard shall not be permitted. Storage of mat erials shall be at least eight feet from the**  **center of railroad tracks. Project managers/field team leaders shall perform a housekee**  **ping review of the work site at the end of each day. All concerns noted will be corrected prior to the field team leaving**  **the site.** 2.14 Manual Lifting **When lifting heavy objects, an improper lifting technique may re sult in a serious injury. When**  **lifting objects, ensure that you:** # **Know your limitation. Enlist help before lifting objects that are beyond your**  **strength.** # **Have cleared a path to carry the object, before lifting the object.** # **Lift with your legs, keeping your back straight.** # **Have a firm grip and a sure footing before lifting the object.** # **Lift objects gradually. Avoid jerking motions and awkward positions.** # **Avoid twisting your body when carrying the object. Turn your entire b ody with the**  **object.** 2.15 Mechanical Lifting **Mechanical lifting aids, such as hoists, trucks, dollies, and jacks ar e to be used to assist Field**  **personnel in handling heavy objects. Field personnel must ensure that:**

# **The rated capacity of the mechanical device is not exceeded.** # **When lifting objects to a higher work location, the area below the lifted object is kept**  **clear by restricting access using ropes, barricades, or other barr iers.**  # **Loads are not left suspended in the air. Raise the load only when it can be unloaded**  **at its destination.** # **Attempts are not made to catch or grab falling objects.** 2.16 Mechanical and Electrical Safety **Analytical Equipment The use and repair of analytical equipment can present unusual electri**  **cal and mechanical hazards. Before performing work on any piece of equipment:** 

# **Ensure that power has been disconnected from the unit.** # **Ensure that any reserve power (capacitors, batteries) are de-energized before working**  **on unit.** # **Do not remove any piece of equipment labelled "Trained Service Personnel Only"**

**. Call the appropriate service organization for repair of the unit.**  **Additional mechanical and electrical hazards may exist. Employ ees must be aware of all hazards**  **before performing any repair work. Employees should consult the cl ient's representative before**  **connecting transformers or other electrical lines to power suppl ies. See Lockout/Tagout procedures**  **in the Supplement of this manual. DEECO Health and Safety Plan Page 20 January 2010** 

2.17 New Employee Orientation **All new employees will undergo initial safety training which i ncludes assigned responsibilities, first**  **aid procedures (including bloodborne pathogens procedures), accident res ponse and reporting**  **procedures, emergency action plan and spill procedures, fire pr otection, general safety rules, and**  **housekeeping. Subsequent safety training will be provided based on job descr iption.** 

2.18 Power and Hand Tools **Improper use of power and hand tools can lead to serious injuries. Field personnel should be familiar**  **with the tools used and their operating manuals. Field personnel should ensure that:**

# **Tools are used for the propose for which they were designed.** # **Power tools must be either grounded or double-insulated.** # **Defective or damaged tools must be labelled and stored such that ot her employees**  **will not mistakenly use the tool.** # **Safety glasses with side shields or goggles must be worn when using power tools that**  **may produce projectiles.** 2.19 Process Safety Management **Many client locations will be required to provide DEECO (the cont ract employee) with process**  **safety management (PSM) information. The processes that requi re PSMs involves a flammable**  **liquid or gas (as defined in OSHA 1926.59(c)) on site in one location, in a quantity of 10,000 pounds**  **(4535.9 kg) or more except for hydrocarbon fuels used solely for workpla ce consumption as a fuel**  **(e.g., propane used for comfort heating, gasoline for vehicle refueling), if suc h fuels are not a part**  **of a process containing another highly hazardous chemical covered by t his standard and flammable**  **liquids stored in atmospheric tanks or transferred which are kept below their normal boiling point**  **without benefit of chilling or refrigeration. PSM describes th e procedures for preventing or**  **minimizing the consequences of catastrophic releases of toxic, r eactive, flammable, or explosive**  **chemicals. These releases may result in toxic, fire or explosion hazards The DEECO project manager/field team leader shall ensure t**  **hat all DEECO employees understand and follow these procedures.**  Management of Change **DEECO work activities at client’s facility may impact on the operation of a PSM regulated process.**  **The DEECO project manager/field team leader and the client’ s facility representative will perform**  **an initial process hazard analysis (hazard evaluation) on process es covered. The process hazard**  **analysis shall be appropriate to the complexity of the proce ss and shall identify, evaluate, and control**  **the hazards involved in the process as they relate to DEECO’s wor k activities. The client’s facility**  **representative shall determine and document the priority order for conducting process hazard**  **analyses based on a rationale which includes such considerations as extent of the process hazards,**  **number of potentially affected employees, age of the process, a nd operating history of the process.**  **The process hazard analysis must be conducted before any work by DEECO is c onducted.** **DEECO Health and Safety Plan Page 21 January 2010**

2.20 Scaffolding Scaffold Erection and Inspection **It is DEECO’s policy** not to **erect scaffolding. Scaffolding is typically the responsibi lity of the**  **client. Scaffolds shall be designed by a qualified person and s hall be constructed and loaded in**  **accordance with that design. Scaffolds shall be erected, moved, dismantled, or alt ered only under**  **the supervision and direction of a competent person qualified in scaf fold erection, moving,**  **dismantling or alteration. Such activities shall be performed only by experienced and trained**  **employees selected for such work by the competent person. Each day before using any scaffolding, ensure that the scaffolding ha**  **s been inspected by a person qualified in scaffold inspection.**  General Requirements for Scaffolding Use **1. The footing or anchorage for scaffolds shall be sound, rigid and c apable of carrying the**  **maximum intended load without settling or displacement. 2. Guardrails and toe-boards shall be installed on all open sides a**  **nd ends of scaffold platforms more than four feet above the ground or floor.**  **3. Scaffolds shall be provided with an access ladder or equivalent safe access**

**. 4. Employees shall not climb or work from scaffold handrails, mid-rails or brac**  **e members. 5. When free-standing manually propelled mobile scaffolds are u**  **sed, the height shall not exceed four times the minimum base dimension.**  **a.Employees shall not ride on mobile scaffolds when they are being moved. 6. All scaffolds shall be inspected by a competent person prior** **to use and shall be acceptance tagged.**  **7. Employees who erect scaffolds shall be trained in the proper means of b uilding scaffolds.**  **8. Employees using scaffolds shall be trained in the safe use of scaffolds. The project manager/field team leader must ensure that all**  **scaffolding is erected in accordance with OSHA regulations and the items listed above.**  **The project manager/field team leader must check with client 's representative to see if additional fall**  **protection is required when working on scaffolding.** Scaffold Use Training **DEECO shall have each employee who performs work while on a sc affold trained by a person**  **qualified in the subject matter to recognize the hazards associa ted with the type of scaffold being**  **used and to understand the procedures to control or minimize those hazards . The training shall**  **include the following areas, as applicable: 1. The nature of any electrical hazards, fall hazards and falling**  **object hazards in the work area; 2. The correct procedures for dealing with electrical hazards and**  **for erecting, maintaining, and disassembling the fall protection systems and falling object**  **protection systems being used; DEECO Health and Safety Plan Page 22 January 2010** 

**3. The proper use of the scaffold, and the proper handling of materials on the scaf fold; and**  **4. The maximum intended load and the load-carrying capacities of the scaffolds used. Additional training will be provided when changes in the types of sc**  **affolds, fall protection, falling object protection, or other equipment present a hazard about which an**  **employee has not been previously trained or when inadequacies in an affected employee's w**  **ork involving scaffolds indicate that the employee has not retained the requisite proficiency.**  2.21 Stairways and Ladders **With regards to stairways and ladders, employees should follow 29 C FR 1910.25, 26, and 27,**  **"Portable Wood Ladders, "Portable Metal Ladders, and Fixed Ladders" , and 1926 Subpart X,**  **"Stairways and Ladders". General Requirements**  **1. A stairway or ladder shall be provided at all personnel points of access where there is a break**  **in elevation of 19 inches or more, and no ramp, runway, sloped embankment or p ersonnel**  **hoist is provided. 2. A double-cleated ladder or two or more separate ladders shall**  **be provided when ladders are the only means of access or egress from a working area for 25 or**  **more employees, or when the ladder is to serve simultaneous two-way traffic.**  **3. When a building or structure has only one point of access between l evels, that point of access**  **shall be kept clear to permit free passage of employees. Stairways**  **1. Stairways that will not be a permanent part of the structur e on which construction work is**  **being performed shall have landings of not less than 30 inches in the di rection of travel and**  **extend at least 22 inches in width at every 12 feet or less of vertical rise. 2. Riser height and tread depth shall be uniform within each flight of stairs.**  **3. Where doors or gates open directly on a stairway, a platform shall be provided, and the swing**  **of the door shall not reduce the effective width of the platform to less than 20 inches. 4. Slippery conditions on stairways shall be eliminated before the sta**  **irways are used to reach other levels.**  **5. Except during stairway construction, foot traffic shall be prohi bited on skeleton metal stairs**  **where the treads and landings are to be filled in at a later da te, unless the stairs are fitted with**  **secured temporary treads and landings long enough to cover the entire t read and landing area.**  **6. Stairways having four or more risers or rising more than 30 inches , whichever is less, shall**  **be equipped with at least one handrail and one system along each unpr otected side or edge.**  **7. Stairrails shall be not less than 36 inches from the upper surf ace of the strairrail system to the**  **surface of the tread. 8. Mid-rails, screens, mesh, intermediate vertical me**  **mbers, or equivalent intermediate structural members, shall be provided between the top rail of the stair**  **rail system and the stair\way steps.** **DEECO Health and Safety Plan Page 23 January 2010**

**9. Handrails and the top rails of stairrail systems shall be capable of withstanding a force of at**  **least 200 pounds applied within two inches of the top edge, in any dow nward or outward**  **direction, at any point along the top edge. 10. Fixed stairways shall conform to the requirements of 29 CFR 1919.24**  **"Fixed Industrial Stairs".**  **Ladders 1. Portable ladders shall be capable of supporting at least f**  **our times the maximum intended load.**  **2. Portable metal or conductive ladders shall not be used near energi zed lines or equipment**  **except as may be necessary in specialized work such as high voltage substations where non**  **conductive ladders might present a greater hazard than conductive ladders. Conductive or**  **metal ladders shall be prominently marked a conductive and all nece ssary precautions shall**  **be taken when used in specialized work. 3. Ladder rungs, cleats and steps shall be parallel, level and unif**  **ormly spaced when the ladder is in position for use.**  **4. The minimum clear distance between side rails for all porta ble ladders shall be 11.5 inches.**  **5. The following requirements apply to the use of all ladders, including job-made la dders.**  **a. Ladders used for access to an upper landing surface, shall have s ide rails that extend**  **at least three feet above the landing surface. b. Ladders shall be maintained free of oil, grease and other slipping hazards.**  **c. Ladders shall be used only for the purpose for which they were designed. d. Non-self-supporting ladders shall be used at an angle such that t**  **he horizontal distance from the top support to the foot of the ladder is approxima**  **tely one-quarter of the working length of the ladder.**  **e. Non-self-supporting ladders shall be tied off or otherwise sec ured to prevent**  **accidental displacement. f. When ascending or descending a ladder, the user shall face the ladde**  **r and shall use at least one hand to grasp the ladder. The user shall not carry a**  **ny object or load that could cause him/her to lose balance and fall.**  **6. Ladders with structural defects, such as broken or missing rungs, shall be tagged DO NOT**  **USE, and shall be withdrawn from service. 7. Ladders will be inspected by a competent person and approved for**  **use before being put into service. Each user shall visually inspect ladder before using.**  **8. Ladders placed in any location where they can be displaced by w orkplace activities or traffic,**  **shall have warning signs posted. Extension Ladders**  **1. After the extension section has been raised to desired height, th e safety latches must be**  **engaged and the extension rope secured to a rung on the base section of the ladder before use.**  **2. Extension ladder sections are not to be used separately. Stepladders**  **1. Must be set level on all four feet, with spreaders locked on pla ce. Do not use as a straight**  **ladder. DEECO Health and Safety Plan Page 24 January 2010** 

**2. When used close to the edge of an elevated platform, roof or floor op ening, and when**  **location requirements so specify, they must be tied off, and employ ees using such a**  **stepladder shall wear fall-arresting equipment. 3. Employees using stepladders shall stand so that their waists**  **are below the top of the ladder. The President shall ensure that all employees are trained in the proper use**  **of ladders.** 2.22 Travel Safety **When driving any DEECO vehicle, or when driving your own personal vehicle when performing**  **DEECO related work, employees must:**

# **Obey all traffic rules and regulations.** # **Obey all traffic rules on a plant site.** # **Turn off vehicle and set brake when leaving vehicle.** # **Use horn at blind driveways or intersections with an obstructive view.** # **Have a valid North Carolina license to operate a DEECO vehicle and trailer.** # **Never pick up hitchhikers.** # **Perform a pre-trip check of vehicle(s) lights, horns, brakes, oil, etc.**

2.23 Thermal Stress **Thermal stress to the body can be caused when the body temperatur e is not in balance between body**  **heat production and heat loss to the surrounding environment. Heat stress is caused when the body**  **is unable to sufficiently cool the body, and cold stress is possibl e when the body is unable to**  **sufficiently heat the body.**

Heat Stress **Heat stress is a general term used to describe various degre es of heat illness. The temperature of the**  **body is a function of the amount of heat it produces and the amount of heat it can los e. When the**  **temperature of the environment approaches the body temperature, it becomes increasingly difficult**  **for the body to lose heat. Heat illness is possible when the body is not able to sufficiently cool itself.**  **The body can lose heat to the environment by three mechanisms. The m ost important is convection.**  **This is when the temperature of the skin is higher than that of the surrounding atmosphere.**  **Conduction is the transfer of heat from the body to a solid or liquid. An example would be the**  **immediate cooling of your face on a hot day by splashing cold wa ter on it. Both convection and**  **conduction can also be negative, meaning that if the atmosphere or ma terial in contact with the body**  **is warmer than the body itself, heat can be transferred to the body. The third, and comparably small, mechanism is respiration. This**  **is the warming and saturation of respired air while in the lungs.** 

Effects of Heat **The body possesses two physiological responses which enable it t o lose heat. The first is the dilation**  **(enlargement) of the blood vessels near the skin surface. This incr eases the flow of blood,**  **transferring heat to the skin. The skin temperature will increa se, and is cooled by either convection**  **on conduction. DEECO Health and Safety Plan Page 25 January 2010** 

**The second response is sweating. Sweating occurs when the increas e in blood flow to the skin does**  **not achieve the desired cooling effect. Heat is lost when sweat is evaporated from the body.** 

Heat Illness **Heat illness can be caused by either elevated body or skin temp eratures. Elevated body temperatures**  **can result in heat exhaustion, heat cramps, and heat stroke. Elevated skin temperatures can cause**  **skin-tissue damage.**

Heat Exhaustion **Heat exhaustion is caused by circulatory failure, where the amount of blood returned to the heart is**  **significantly reduced. Symptoms of heat exhaustion are fatigue, he adache, dizziness, loss of**  **appetite, nausea, abdominal pain, vomiting, shortness of breath, and puls e rates in excess of 150**  **beats per minute. Heat exhaustion can result in poor judgement, irri tability, and possibly fainting.**  **A person suffering from heat exhaustion can usually recover very quic kly if he/she is removed to a**  **cool place and allowed to lie down.** Heat Cramps **Heat cramps are muscle spasms which usually occur in the arm s, legs, back and abdomen. This is**  **due to excessive loss of salt from sweating. Heat cramps ca n be prevented by taking extra salt when**  **heavy work is carried out. It is recommended that employees do not take salt tablets, but rather**  **ensure that they eat at regular intervals during the course of the work, Extra salt can by added to the**  **body through eating.**

Heat Stroke **The most serious heat illness is heat stroke. When the body tem perature reaches a certain level,**  **sweating may stop. This will cause the body temperature to increase to critical levels. Such an**  **increase in body temperature can cause denaturization of proteins, enzyme degradation, changes in**  **the viscosity of cell protoplasm, and alterations in the physica l structure of the cell membranes.**  **Tissue damage and death are possible. Immediate medical attention is necessary for individuals sufferi**  **ng from heat stroke in order to avoid irreversible damage to the brain. The individual should be wrapped i**  **n cool, wet sheets. Immersion in a cold bath is not recommended, since a too rapid decrease in the**  **body temperature may result in tissue damage.** 

Precautions **1. Water intake must equal the amount of water lost due to sweat ing and excretion. In hot**  **environments, water intake must be forced since the body's normal thi rst mechanism is not**  **adequate to force the individual to drink. Continuous sweat rates of 1 to 2 liter s per hours**  **are not unusual. 2. Salt is lost during sweating. Additions of small amounts of salt to food may be nece**  **ssary. 3. Most importantly, frequent, short breaks during strenuous activities**  **allows the body to better adapt to the hot environment than infrequent long breaks. By taking shorte**  **r breaks, there is less cumulative fatigue and less demand on the heart and respiration.**  **4. It is possible for the body to acclimatize to hot environments. This may happen only if**  **successive days are spent in the hot environment (usually between 4 to 7). DEECO Health and Safety Plan Page 26 January 2010** 

Cold Stress **In cold environments, the body must increase its metabolic heat pro duction. In general, -30**  E **F is the lower limit for prolonged work. Unlike hot environments, individuals do**  **not acclimatize (physiologically adapt) to cold environments.**  **The wind-chill temperature, rather than the ambient temperature , best describe a cold environment.**  **Wind velocity adds to the rate of body cooling.**

Cold Illness Hypothermia **Hypothermia is a general cooling of the body temperature. Hypot hermia can occur in environments**  **above 32** E **F. Symptoms include excessive shivering, and numbness in extremiti es. The individual**  **should be moved to a warm environment. Alcohol should not be consumed, since t his will cause**  **the blood vessel to dilate, resulting in excessive body heat loss. Hot, non-alcoholic beverages should**  **be administered.**

Frost Bite **Frost bite can be either superficial or can penetrate be low the skin. Superficial frost bite can be**  **easily treated by warming the exposed skin with hands or other wa rmer part of the body (e.g. placing**  **hands under armpits). This will gradually warm the skin. Rapid w arming (exposure to fire, soaking**  **in cold water etc.) is not recommended since damage to the skin tis sue can occur. It is important to**  **note that pain will occur as the skin is thawed. When frost bite extends below the surface of the skin (from prolonged exposure**  **), it is essential to get immediate medical attention.** 

Precautions **1. Individuals should eat balanced meals and replace body liquids regula rly. Dehydration is as**  **prevalent in cold environments as it is in hot environments. Warm li quids are preferable**  **since they do not have to be warmed by the body after being consumed. 2. Proper protective clothing should be worn when exposed to cold environments.**  **3 Dexterity and judgement are both diminished in cold environments.** 2.24 Welding and Cutting **DEECO employees shall not perform any welding or cutting on a p roject site. The project**  **manager/field team leader shall ensure that the client contrac ts such work with qualified individuals.**  **DEECO employees shall leave the immediate area during any welding or cutting operations.**  2.26 Lockout/Tagout (LOTO) **Lockout/Tagout (LOTO) refers to specific practices and procedur es to safeguard employees from**  **the unexpected energization or startup of machinery and equipme nt, or the release of hazardous**  **energy during service or maintenance activities.** Under no circumstance should DEECO employee’s participate in LOTO **. Should any LOTO be necessary at a client’s facility, all LOTO**  **procedures are to be handled by the client or their representative. DEECO Health and Safety Plan Page 27 January 2010** 

2.27 Fall Protection 2.27.1 Determining When Fall Protection Must be Provided **DEECO shall determine if the walking/working surfaces on which it s employees are to work have**  **the strength and structural integrity to support employees safe ly. Employees shall be allowed to work**  **on those surfaces only when the surfaces have the requisite strength and structural int egrity.**  **Each employee on a walking/working surface (horizontal and vertical surface) with an unprotected**  **side or edge which is 6 feet (1.8 m) or more above a lower level shall be prot ected from falling by**  **the use of guardrail systems, safety net systems, or personal fall arres t systems.**  Hoist Areas **Each employee in a hoist area shall be protected from falling 6 feet (1.8 m) or more to lower levels**  **by guardrail systems or personal fall arrest systems. If guardrail systems, [or chain, gate, or guardrail]**  **or portions thereof, are removed to facilitate the hoisting ope ration (e.g., during landing of**  **materials), and an employee must lean through the access opening or out over the edge of the access**  **opening (to receive or guide equipment and materials, for example ), that employee shall be protected**  **from fall hazards by a personal fall arrest system.**

Holes **Each employee on walking/working surfaces shall be protecte d from falling through holes (including**  **skylights) more than 6 feet (1.8 m) above lower levels, by persona l fall arrest systems, covers, or**  **guardrail systems erected around such holes. Each employee on a walking/working surface shall be protected fr**  **om tripping in or stepping into or through holes (including skylights) by covers.**  **Each employee on a walking/working surface shall be protected fr om objects falling through holes**  **(including skylights) by covers.** Formwork and Reinforcing Steel **Each employee working on the face of formwork or reinforcing steel shall be protected from falling**  **6 feet (1.8 m) or more to lower levels by personal fall arrest systems, safety net systems, or**  **positioning device systems.** Ramps, Runways, and Other Walkways **Each employee on ramps, runways, and other walkways shall be protected from falling 6 feet (1.8**  **m) or more to lower levels by guardrail systems. DEECO Health and Safety Plan Page 28 January 2010** 

Excavations **Each employee at the edge of an excavation 6 feet (1.8 m) or more in depth shall be protected from**  **falling by guardrail systems, fences, or barricades when the e xcavations are not readily seen because**  **of plant growth or other visual barrier. Each employee at the edge of a well, pit, shaft, and similar e**  **xcavation 6 feet (1.8 m) or more in depth shall be protected from falling by guardrail systems, fences, barr**  **icades, or covers.** Dangerous Equipment **Each employee less than 6 feet (1.8 m) above dangerous equipment shal l be protected from falling**  **into or onto the dangerous equipment by guardrail systems or by equipment guards. Each employee 6 feet (1.8 m) or more above dangerous equipment shall**  **be protected from fall hazards by guardrail systems, personal fall arrest systems, or safe**  **ty net systems.** Overhand Bricklaying and Related Work **Currently, DEECO does not perform overhand bricklaying, so any fall p rotection programs related**  **to overhand brick are not applicable.** Working on Roofs **Each employee engaged in any activities on low-slope roofs (slo pe less than 4 in 12), with**  **unprotected sides and edges 6 feet (1.8 m) or more above lower level s shall be protected from falling**  **by guardrail systems, safety net systems, personal fall arres t systems, or a combination of warning**  **line system and guardrail system, warning line system and safe ty net system, or warning line system**  **and personal fall arrest system, or warning line system and safety monitori ng system.**  **Each employee on a steep roof (slope greater than 4 in 12) with unprotected sides and edges 6 feet**  **(1.8 m) or more above lower levels shall be protected from fa lling by guardrail systems with**  **toeboards, safety net systems, or personal fall arrest systems.**

Precast Concrete Erection **Currently, DEECO does not perform precast concrete erection, so a ny fall protection programs**  **related to precast concrete erection are not applicable.**

Residential Construction **Currently, DEECO does not perform residential construction, so any fa ll protection programs related**  **to residential construction are not applicable. DEECO Health and Safety Plan Page 29 January 2010** 

Wall Openings **Each employee working on, at, above, or near wall openings (including t hose with chutes attached)**  **where the outside bottom edge of the wall opening is 6 feet (1.8 m) or more above lower levels and**  **the inside bottom edge of the wall opening is less than 39 inches ( 1.0 m) above the walking/working**  **surface, shall be protected from falling by the use of a guar drail system, a safety net system, or a**  **personal fall arrest system.** Walking/Working Surfaces Not Otherwise Addressed (e.g Man Lifts) **When operating or working on any man lifts that fall under the ANS I standard definition that**  **includes certain vehicle-mounted elevating and rotating work platforms , namely "extensible boom**  **platforms," "aerial ladders," "articulating boom platforms," " vertical towers," and "a combination**  **of any of the above.", DEECO employees shall be protected from f alling by a personal fall arrest**  **system. For all other walking/working surfaces not otherwise addressed, each**  **employee on a walking/working surface 6 feet (1.8 m) or more above lower levels shall be**  **protected from falling by a guardrail system, safety net system, or personal fall arrest sys**  **tem.** Protection from Falling Objects **When an employee is exposed to falling objects, the employer sha ll have each employee wear a hard**  **hat and shall erect toeboards, screens, or guardrail systems to p revent objects from falling from**  **higher levels, erect a canopy structure and keep potential fall objects far enough from the edge of the**  **higher level so that those objects would not go over the edge if they were accidentally displaced; or,**  **barricade the area to which objects could fall, prohibit employe es from entering the barricaded area,**  **and keep objects that may fall far enough away from the edge of a higher level so that those objects**  **would not go over the edge if they were accidentally displaced. The project manager/field team leader must check with clien**  **t's representative to see if additional barricade procedures specific to their facility are required.**  2.27.2 Guidelines for Fall Protection **The DEECO project manager/field team in conjunction with the client's representative shall**  **determine when additional fall protection is required. The client shall provide and install all Guard Rail Systems, Sa**  **fety Net Systems, Positioning Device Systems and Warning Line Systems required for DEECO an employ**  **ee, and shall comply with all other pertinent requirements of described below before that empl**  **oyee begins the work that necessitates the fall protection.**  Guardrail Systems **Top edge height of top rails, or equivalent guardrail system me mbers, shall be 42 inches (1.1 m) plus**  **or minus 3 inches (8 cm) above the walking/working level. When conditions w arrant, the height of** **DEECO Health and Safety Plan Page 30 January 2010**

**the top edge may exceed the 45-inch height, provided the guardrail system meets all other criteria**  **of this paragraph. Note: When employees are using stilts, the top edge height of t**  **he top rail, or equivalent member, shall be increased an amount equal to the height of the stilts.**  **Midrails, screens, mesh, intermediate vertical members, or equiva lent intermediate structural**  **members shall be installed between the top edge of the guardrail s ystem and the walking/working**  **surface when there is no wall or parapet wall at least 21 inches (53 cm) high. Midrails, when used, shall be installed at a height midway be**  **tween the top edge of the guardrail system and the walking/working level.**  **Screens and mesh, when used, shall extend from the top rail to the w alking/working level and along**  **the entire opening between top rail supports. Intermediate members (such as balusters), when used between p**  **osts, shall be not more than 19 inches (48 cm) apart.**  **Other structural members (such as additional midrails and archit ectural panels) shall be installed**  **such that there are no openings in the guardrail system that are more than 19 inches (.5 m ) wide.**  **Guardrail systems shall be capable of withstanding, without failure, a f orce of at least 200 pounds**  **(890 N) applied within 2 inches (5.1 cm) of the top edge, in any outward or downward direction, at**  **any point along the top edge. When the 200 pound (890 N) test load specified above is applied in a downwa**  **rd direction, the top edge of the guardrail shall not deflect to a height less than 39 inc**  **hes (1.0 m) above the walking/working level.**  **Midrails, screens, mesh, intermediate vertical members, solid p anels, and equivalent structural**  **members shall be capable of withstanding, without failure, a f orce of at least 150 pounds (666 N)**  **applied in any downward or outward direction at any point along the midrail or other membe r.**  **Guardrail systems shall be so surfaced as to prevent injury to an employee from punctures or**  **lacerations, and to prevent snagging of clothing. The ends of all top rails and midrails shall not overhang the term**  **inal posts, except where such overhang does not constitute a projection hazard.**  **Steel banding and plastic banding shall not be used as top rails or midrail s.**  **Top rails and midrails shall be at least one-quarter inch (0.6 cm) nominal diam eter or thickness to**  **prevent cuts and lacerations. If wire rope is used for top rai ls, it shall be flagged at not more than 6-**  **foot intervals with high-visibility material. When guardrail systems are used at hoisting areas, a chain, gate**  **or removable guardrail section shall be placed across the access opening between guardrail sect**  **ions when hoisting operations are not taking place.** **DEECO Health and Safety Plan Page 31 January 2010**

**When guardrail systems are used at holes, they shall be erecte d on all unprotected sides or edges of**  **the hole. When guardrail systems are used around holes used for the passage of**  **materials, the hole shall have not more than two sides provided with removable guardrail sections to**  **allow the passage of materials. When the hole is not in use, it shall be closed over wit**  **h a cover, or a guardrail system shall be provided along all unprotected sides or edges.**  **When guardrail systems are used around holes which are used as poi nts of access (such as**  **ladderways), they shall be provided with a gate, or be so offset that a person cannot walk directly into**  **the hole. Guardrail systems used on ramps and runways shall be erected al**  **ong each unprotected side or edge. Manila, plastic or synthetic rope being used for top rails or**  **midrails shall be inspected as frequently as necessary to ensure that it continues to meet the strength re**  **quirements of paragraph (b)(3) of this section.**  Safety Net Systems **Safety nets shall be installed as close as practicable unde r the walking/working surface on which**  **employees are working, but in no case more than 30 feet (9.1 m) below such le vel. When nets are**  **used on bridges, the potential fall area from the walking/wor king surface to the net shall be**  **unobstructed. Safety nets shall extend outward from the outermost projection of the work surfac**  **e as follows: Vertical distance from working level to**  **horizontal plane of net Minimum required horizontal distance of**  **outer edge of net from the edge of the**

**working surface Up to 5 feet 8 feet**  **More than 5 feet up to 10 feet 10 feet More than 10 feet 13 feet**  **Safety nets shall be installed with sufficient clearance under them to prevent contact with the surface**  **or structures below when subjected to an impact force equal to the drop test described below. Safety**  **nets and their installations shall be capable of absorbing an i mpact force equal to that produced by**  **the drop test described below. Except as described below, safety nets and safety net instal**  **lations shall be drop-tested at the jobsite after initial installation and before being used as a fall pr**  **otection system, whenever relocated, after major repair, and at 6-month intervals if left in one place. The dr**  **op-test shall consist of a 400 pound (180 kg) bag of sand 30 + or - 2 inches (76 + or - 5 cm) in diameter dropped i**  **nto the net from the highest walking/working surface at which employees are exposed t**  **o fall hazards, but not from less than 42 inches (1.1 m) above that level.** **DEECO Health and Safety Plan Page 32 January 2010**

**When the employer can demonstrate that it is unreasonable to perform the drop-test, the employer**  **(or a designated competent person) shall certify that the net a nd net installation is in compliance with**  **the provisions of paragraphs (c)(3) and (c)(4)(i) of this secti on by preparing a certification record**  **prior to the net being used as a fall protection system. The c ertification record must include an**  **identification of the net and net installation for which the certifi cation record is being prepared; the**  **date that it was determined that the identified net and net instal lation were in compliance with**  **paragraph (c)(3) of this section and the signature of the person m aking the determination and**  **certification. The most recent certification record for each net and net installation shall be available**  **at the jobsite for inspection. Defective nets shall not be used. Safety nets shall be inspect**  **ed at least once a week for wear, damage, and other deterioration. Defective components shall be removed**  **from service. Safety nets shall also be inspected after any occurrence which could affect**  **the integrity of the safety net system. Materials, scrap pieces, equipment, and tools which have fallen int**  **o the safety net shall be removed as soon as possible from the net and at least before the next work shift.**  **The maximum size of each safety net mesh opening shall not exc eed 36 square inches (230 cm) nor**  **be longer than 6 inches (15 cm) on any side, and the opening, measur ed center-to-center of mesh**  **ropes or webbing, shall not be longer than 6 inches (15 cm). All mes h crossings shall be secured to**  **prevent enlargement of the mesh opening. Each safety net (or section of it) shall have a border rope f**  **or webbing with a minimum breaking strength of 5,000 pounds (22.2 kN).**  **Connections between safety net panels shall be as strong as int egral net components and shall be**  **spaced not more than 6 inches (15 cm) apart.** Personal Fall Arrest Systems **Personal fall arrest systems shall consist of a full body har ness. Body belts are not acceptable as part**  **of a personal fall arrest system except in a positioning device system as described below.**  **Connectors shall be drop forged, pressed or formed steel, or made of equivalent materials and shall**  **have a corrosion-resistant finish. All surfaces and edges sha ll be smooth to prevent damage to**  **interfacing parts of the system. Dee-rings and snaphooks shall have a minimum tensile strength of 5,000 pounds**  **(22.2 kN) and shall be proof-tested to a minimum tensile load of 3,600 pounds (16 kN) without cra**  **cking, breaking, or taking permanent deformation.**  **Snaphooks shall be sized to be compatible with the member to whi ch they are connected to prevent**  **unintentional disengagement of the snaphook by depression of the snaphoo k keeper by the connected**  **member, or shall be a locking type snaphook designed and used to prev ent disengagement of the**  **snaphook by the contact of the snaphook keeper by the connected mem ber. Only locking type**  **snaphooks shall be used. DEECO Health and Safety Plan Page 33 January 2010** 

**Unless the snaphook is a locking type and designed for the following conne ctions, snaphooks shall**  **not be engaged directly to webbing, rope or wire rope, to each ot her, to a dee-ring to which another**  **snaphook or other connector is attached, to a horizontal lifeline; or to a ny object which is**  **incompatibly shaped or dimensioned in relation to the snaphook such that unintentional**  **disengagement could occur by the connected object being able to depr ess the snaphook keeper and**  **release itself. On suspended scaffolds or similar work platforms with horizontal l**  **ifelines which may become vertical lifelines, the devices used to connect to a horizontal lifeline shal**  **l be capable of locking in both directions on the lifeline. Horizontal lifelines shall be des**  **igned, installed, and used, under the supervision of a qualified person, as part of a complete personal**  **fall arrest system, which maintains a safety factor of at least two.**  **Lanyards and vertical lifelines shall have a minimum breaking st rength of 5,000 pounds (22.2 kN).**  **Lifelines shall be protected against being cut or abraded. Se lf-retracting lifelines and lanyards which**  **automatically limit free fall distance to 2 feet (0.61 m) or less shall be capable of sustaining a**  **minimum tensile load of 3,000 pounds (13.3 kN) applied to the device with the lifeline or lanya rd**  **in the fully extended position. Self-retracting lifelines and lanyards which do not limit free**  **fall distance to 2 feet (0.61 m) or less, ripstitch lanyards, and tearing and deforming lanyards shall be ca**  **pable of sustaining a minimum tensile load of 5,000 pounds (22.2 kN) applied to the device with the lifeli**  **ne or lanyard in the fully extended position.**  **Ropes and straps (webbing) used in lanyards, lifelines, and streng th components of body belts and**  **body harnesses shall be made from synthetic fibers. Anchorages used for attachment of personal fall arrest equipment**  **shall be independent of any anchorage being used to support or suspend platforms and capable of**  **supporting at least 5,000 pounds (22.2 kN) per employee attached, or shall be designed, install**  **ed, and used as part of a complete personal fall arrest system which maintains a saf**  **ety factor of at least two and under the supervision of a qualified person.**  **Personal fall arrest systems, when stopping a fall, shall limit maximum arresting force on an**  **employee to 900 pounds (4 kN) when used with a body belt, limit maximum arresting force on an**  **employee to 1,800 pounds (8 kN) when used with a body harness, be rigged s uch that an employee**  **can neither free fall more than 6 feet (1.8 m), nor contact any lower level, bring an employee to a**  **complete stop and limit maximum deceleration distance an emp loyee travels to 3.5 feet (1.07 m)**  **and, have sufficient strength to withstand twice the potential impa ct energy of an employee free**  **falling a distance of 6 feet (1.8 m), or the free fall distance permitted by the system, whichever is**  **less. The attachment point of the body belt shall be located in the cen**  **ter of the wearer's back. The attachment point of the body harness shall be located in the center**  **of the wearer's back near shoulder level, or above the wearer's head.**  **Body belts, harnesses, and components shall be used only for employee protection (as part of a**  **personal fall arrest system or positioning device system) and not to hoist mat erials.** **DEECO Health and Safety Plan Page 34 January 2010**

**Personal fall arrest systems and components subjected to imp act loading shall be immediately**  **removed from service and shall not be used again for employee prot ection until inspected and**  **determined by a competent person to be undamaged and suitable for reuse. The employer shall provide for prompt rescue of employees in the**  **event of a fall or shall assure that employees are able to rescue themselves.**  **Personal fall arrest systems shall be inspected prior to e ach use for wear, damage and other**  **deterioration, and defective components shall be removed from service. Body belts shall be at least one and five-eighths (1 5/8) inches (4.1 cm) wide.**  **Personal fall arrest systems shall not be attached to guardra il systems, nor shall they be attached to**  **hoists. When a personal fall arrest system is used at hoist a reas, it shall be rigged to allow the**  **movement of the employee only as far as the edge of the walking/working surface.** Positioning Device Systems **Positioning device systems shall be rigged such that an employee cannot free fall more than 2 feet**  **(.9 m). Positioning devices shall be secured to an anchorage capabl e of supporting at least twice the**  **potential impact load of an employee's fall or 3,000 pounds (13.3 kN), whichever is great er.**  **Connectors shall be drop forged, pressed or formed steel, or made of equivalent materials and shall**  **have a corrosion-resistant finish. All surfaces and edges shall be smooth to prevent damage to**  **interfacing parts of this system. Connecting assemblies shall have a minimum tensile strength of**  **5,000 pounds (22.2 kN). Dee-rings and snaphooks shall be proof-tested to a minimum tensile**  **load of 3,600 pounds (16 kN) without cracking, breaking, or taking permanent deformation.**  **Snaphooks shall be sized to be compatible with the member to whi ch they are connected to prevent**  **unintentional disengagement of the snaphook by depression of the snaphook keeper by the connected**  **member, or shall be a locking type snaphook designed and used to preven t disengagement of the**  **snaphook by the contact of the snaphook keeper by the connected member. A s of January 1, 1998,**  **only locking type snaphooks shall be used. Unless the snaphook is a locking type and designed for the following conne**  **ctions, snaphooks shall not be engaged directly to webbing, rope or wire rope, to each ot**  **her, to a dee-ring to which another snaphook or other connector is attached, to a horizontal lifeline;**  **or to any object which is incompatibly shaped or dimensioned in relation to the snaphook such t**  **hat unintentional disengagement could occur by the connected object being able to depr**  **ess the snaphook keeper and release itself.**  **Positioning device systems shall be inspected prior to each use for wear, damage, and other**  **deterioration, and defective components shall be removed from service. Body belts, harnesses, and components shall be used only for employee**  **protection (as part of a personal fall arrest system or positioning device system) and not to hoist mat**  **erials. DEECO Health and Safety Plan Page 35 January 2010** 

Warning Line Systems **Warning line systems shall be erected around all sides of the r oof work area. When mechanical**  **equipment is not being used, the warning line shall be erected not l ess than 6 feet (1.8 m) from the**  **roof edge. When mechanical equipment is being used, the warning line shall be erected not less than**  **6 feet (1.8 m) from the roof edge which is parallel to the direct ion of mechanical equipment**  **operation, and not less than 10 feet (3.1 m) from the roof edge which is perpendicular to the direction**  **of mechanical equipment operation. Points of access, materials handling areas, storage areas, and hoi**  **sting areas shall be connected to the work area by an access path formed by two warning lines. When t**  **he path to a point of access is not in use, a rope, wire, chain, or other barricade, equivalent in strengt**  **h and height to the warning line, shall be placed across the path at the point where the path int**  **ersects the warning line erected around the work area, or the path shall be offset such that a person cannot**  **walk directly into the work area. Warning lines shall consist of ropes, wires, or chains, and supporti**  **ng stanchions erected as follows: 1. The rope, wire, or chain shall be flagged at not more than 6-foot**  **(1.8 m) intervals with high visibility material;**  **2. The rope, wire, or chain shall be rigged and supported in such a w ay that its lowest point**  **(including sag) is no less than 34 inches (.9 m) from the walking/worki ng surface and its**  **highest point is no more than 39 inches (1.0 m) from the walking/working surface; 3. After being erected, with the rope, wire, or chain attached**  **, stanchions shall be capable of resisting, without tipping over, a force of at least 16 pounds (71**  **N) applied horizontally against the stanchion, 30 inches (.8 m) above the walking/working surface**  **, perpendicular to the warning line, and in the direction of the floor, roof, or platform edge;**  **4. The rope, wire, or chain shall have a minimum tensile strength of 500 pounds (2.22 kN), and**  **after being attached to the stanchions, shall be capable of sup porting, without breaking, the**  **loads applied to the stanchions as described above; and 5. The line shall be attached at each stanchion in such a way that**  **pulling on one section of the line between stanchions will not result in slack being taken up i**  **n adjacent sections before the stanchion tips over.**  **No employee shall be allowed in the area between a roof edge a nd a warning line unless the**  **employee is performing roofing work in that area. Mechanical equipment on roofs shall be used or stored only in areas w**  **here employees are protected by a warning line system, guardrail system, or personal fall arrest sys**  **tem.** Controlled Access Zone **When used to control access to areas where leading edge and other opera tions are taking place the**  **controlled access zone shall be defined by a control line or by any other means that restricts access.** **DEECO Health and Safety Plan Page 36 January 2010**

**When control lines are used, they shall be erected not less than 6 f eet (1.8 m) nor more than 25 feet**  **(7.7 m) from the unprotected or leading edge, except when erecting precast concrete members.**  **DEECO does not erecting precast concrete members. The control line shall extend along the entire**  **length of the unprotected or leading edge and shall be approximatel y parallel to the unprotected or**  **leading edge. The control line shall be connected on each side to a guardrail system or wall.**  **Additional control lines shall be erected at each end to enclose the controlled acce ss zone.**  **Control lines shall consist of ropes, wires, tapes, or equivalent m aterials, and supporting stanchions.**  **Each line shall be flagged or otherwise clearly marked at not more than 6-foot (1.8 m) intervals with**  **high-visibility material. Each line shall be rigged and suppor ted in such a way that its lowest point**  **(including sag) is not less than 39 inches (1 m) from the walking/wor king surface and its highest**  **point is not more than 45 inches (1.3 m) from the walking/working surface . Each line shall have a**  **minimum breaking strength of 200 pounds (.88 kN).** Safety Monitoring Systems **DEECO shall designate a competent person as the safety monitor . The safety monitor will monitor**  **the safety of other employees. The safety monitor shall be com petent to recognize fall hazards. The**  **safety monitor shall warn the employee when it appears that the employee is unaware of a fall hazard**  **or is acting in an unsafe manner. The safety monitor shall be on t he same walking/working surface**  **and within visual sighting distance of the employee being monitored. The safety moni tor shall be**  **close enough to communicate orally with the employee. The safety monitor shall not have other**  **responsibilities which could take the monitor's attention from the monitoring functi on.**  **Mechanical equipment shall not be used or stored in areas where sa fety monitoring systems are being**  **used to monitor employees engaged in roofing operations on low-slope roofs. No employee, other**  **than an employee engaged in roofing work [on low-sloped roofs] or an em ployee covered by a fall**  **protection plan, shall be allowed in an area where an employee i s being protected by a safety**  **monitoring system. Each employee working in a controlled access zone shall be direct**  **ed to comply promptly with fall hazard warnings from safety monitors.** 

Covers **Covers located in roadways and vehicular aisles shall be capable of supporting , without failure, at**  **least twice the maximum axle load of the largest vehicle ex pected to cross over the cover. All other**  **covers shall be capable of supporting, without failure, at leas t twice the weight of employees,**  **equipment, and materials that may be imposed on the cover at any one time. All covers shall be**  **secured when installed so as to prevent accidental displacement b y the wind, equipment, or**  **employees. All covers shall be color coded or they shall be ma rked with the word "HOLE" or**  **"COVER" to provide warning of the hazard.** Protection from Falling Objects **Toeboards, when used as falling object protection, shall be erected al ong the edge of the overhead**  **walking/working surface for a distance sufficient to protect employee s below. Toeboards shall be** **DEECO Health and Safety Plan Page 37 January 2010**

**capable of withstanding, without failure, a force of at least 50 pounds (222 N) applied in any**  **downward or outward direction at any point along the toeboard. Toeboards s hall be a minimum of**  **3 1/2 inches (9 cm) in vertical height from their top edge to the level of the walking/working surface.**  **They shall have not more than 1/4 inch (0.6 cm) clearance above the wal king/working surface. They**  **shall be solid or have openings not over 1 inch (2.5 cm) in greatest dimension. Where tools,**  **equipment, or materials are piled higher than the top edge of a toeboard, paneling or screening shall**  **be erected from the walking/working surface or toeboard to the top of a guardra il system's top rail**  **or midrail, for a distance sufficient to protect employees below. Guardrail systems, when used as**  **falling object protection, shall have all openings small enough to prevent passage of potential falling**  **objects. Canopies, when used as falling object protection, shall be strong**  **enough to prevent collapse and to prevent penetration by any objects which may fall onto the canopy.** 

Fall Protection Plan **This option is available only to employees engaged in leading edge work that it is infeasible or it**  **creates a greater hazard to use conventional fall protection equipment. The fall protection plan shall be prepared by a qualified per**  **son and developed specifically for the site where the leading edge work, precast concrete work, or residential constr**  **uction work is being performed and the plan must be maintained up to date. Any changes t**  **o the fall protection plan shall be approved by a qualified person. A copy of the fall protection**  **plan with all approved changes shall be maintained at the job site. The implementation of the fal**  **l protection plan shall be under the supervision of a competent person. The fall protection plan shall**  **document the reasons why the use of conventional fall protection systems (guardrail systems, pers**  **onal fall arrest systems, or safety nets systems) are infeasible or why their use would create a greater hazard.**  **The fall protection plan shall include a written discussion of ot her measures that will be taken to**  **reduce or eliminate the fall hazard for workers who cannot be provide d with protection from the**  **conventional fall protection systems. For example, the employer s hall discuss the extent to which**  **scaffolds, ladders, or vehicle mounted work platforms can be used to pr ovide a safer working surface**  **and thereby reduce the hazard of falling. The fall protection plan shall identify each location where convent**  **ional fall protection methods cannot be used. These locations shall then be classified as controll**  **ed access zones. Where no other alternative measure has been implemented, the employer shall**  **implement a safety monitoring system.**  **The fall protection plan must include a statement which provides the name or other method of**  **identification for each employee who is designated to work in cont rolled access zones. No other**  **employees may enter controlled access zones. In the event an employee falls, or some other related, serious inci**  **dent occurs, (e.g., a near miss) the employer shall investigate the circumstances of the fall or ot**  **her incident to determine if the fall protection plan needs to be changed (e.g. new practices, procedures,**  **or training) and shall implement those changes to prevent similar types of falls or incidents.** **DEECO Health and Safety Plan Page 38 January 2010**

2.27.3 Fall Protection Training Program **DEECO shall provide a training program for each employee who mi ght be exposed to fall hazards.**  **The program shall enable each employee to recognize the haza rds of falling and shall train each**  **employee in the procedures to be followed in order to minimize these hazards. DEECO shall assure that each employee has been trained, as**  **necessary, by a competent person qualified in the nature of fall hazards in the work area, the correc**  **t procedures for erecting, maintaining, disassembling, and inspecting the fall protection sy**  **stems to be used, the use and operation of guardrail systems, personal fall arrest system**  **s, safety net systems, warning line systems, safety monitoring systems, controlled access zones, and other protec**  **tion to be used, the role of each employee in the safety monitoring system when this system**  **is used, the limitations on the use of mechanical equipment during the performance of roofing work on low-slo**  **ped roofs, the correct procedures for the handling and storage of equipment and materials and**  **the erection of overhead protection; and the role of employees in fall protection plans.**  Certification of Training **DEECO shall verify compliance with the Fall Protection Training Program by preparing a written**  **certification record. The written certification record shall contain the na me or other identity of the**  **employee trained, the date(s) of the training, and the signature of the person who conducted the**  **training or the signature of the employer. If training is conducted b y another employer, the**  **certification record shall indicate the date the employer deter mined the prior training was adequate**  **rather than the date of actual training. The latest training certification shall be maintained.**  Retraining **When DEECO has reason to believe that any affected employee who has already been trained does**  **not have the understanding and skill required by the Fall Protection Tra ining Program, DEECO shall**  **retrain each such employee. Circumstances where retraining is required include, but are not limited**  **to, situations where changes in the workplace render previous traini ng obsolete, changes in the types**  **of fall protection systems or equipment to be used render previous training obsolete, or inadequacies**  **in an affected employee's knowledge or use of fall protection sys tems or equipment indicate that the**  **employee has not retained the requisite understanding or skill.** 2.28 Combustible Gas (LEL), Carbon Monoxide, Hydrogen Sulfide, and/or Oxygen Monitors **For safe operation around processes involving combustible material s, a hot work permit may be**  **required. Hot work permits (HWPs) are required for any process where testing activities may**  **produce an ignition source in a work area in which flammable vapors or gases may be present. To**  **issue an HWP, a hazard assessment must be performed. To do so, combus tible gas and vapor**  **concentrations must be determined for the work area and job classi fication in question, then**  **compared to acceptable standards. These surveys typically invol ve the use of combustible gas**  **meters-also called lower explosive limit (LEL) meters. The se surveys are conducted by the client**  **personnel issuing the hot work permits . DEECO Health and Safety Plan Page 39 January 2010** 

**To perform the surveys properly, the facility will have work i nstructions and standard operating**  **procedures (SOPs) developed, implemented and documented. Training in LEL instrument use,**  **instrument calibration, sampling strategy, continuous or follow-up monitor ing, tracking of denied**  **permits, communication between departments related to the content of processes, documentation of**  **results, auditing of hot work permit procedures and results, and the cont inuous improvement of those**  **SOPs will be addressed. In some cases DEECO will be required to provide additional monitori**  **ng for LEL, carbon monoxide, hydrogen sulfide, and/or oxygen. For these situations, DEECO personnel will be t**  **rained in LEL, carbon monoxide, hydrogen sulfide, and/or oxygen instrument use and instrument calibration.**  Training in Instrument Use **Thorough, documented training will be performed for the use of LEL, ca rbon monoxide, hydrogen**  **sulfide, and/or oxygen meters. Thus, training programs for operat ors of LEL, carbon monoxide,**  **hydrogen sulfide, and/or oxygen meters will include: 1. Work instructions for basic instrument use;**  **2. Theory of instrument operation; 3 Instrument maintenance and calibration; and**  **4. Recordkeeping for calibration and maintenance.**

Instrument Calibration **The instrument manufacturers detail procedures for calibrating LEL, c arbon monoxide, hydrogen**  **sulfide, and/or oxygen meters will be followed. Calibration includes; 1. Clean air-zero point calibration;**  **2. Calibration of response with the appropriate span gas; 3. Checking and calibration, for actively pumped meters, of the air flow rate in t**  **he system; 4. Fault detection and subsequent maintenance; and**  **5. Record keeping. Any decisions made to extend the period between calibrations or to**  **lessen the rigor of calibrations must first be formally evaluated by qualified persons against**  **the manufacturer's recommendations, industry best practices and governmental regulations. Requirements**  **for specified, periodic calibration of zero, span and flow are mandates, not recommendations. T**  **his applies for all systems, but is especially critical for systems used in environments w**  **here air contaminants that may degrade the meter's sensing element may be present.** **DEECO Health and Safety Plan Page 40 January 2010**

**For gases and vapors other than those for which a device was calibr ated, the manufacturer's**  **instructions and correction curves should be consult. Variations in re sponse that may result in**  **incorrect readings from such interferences as: 1. Oxygen concentration;**  **2. Gas pressure; 3. Sensor poisons (i.e., silicon, silicates and organic lead, acid g**  **ases) and sensor depressants (i.e., chlorinated hydrocarbons, acid gases); and**  **4. The fact that no reading will occur, or is even possible, for t he detection of combustible**  **airborne mists or dusts, such as lubricating oils, coal dust or grain dust. The portion of the calibration that deals with instrument airflow**  **rate must include the blocked flow alarm must being tested before and after each use. While this**  **is a requirement for all such systems, it is especially critical for instruments used in dusty environments.**  Sampling Strategy **Measurement of values for each atmospheric parameter should be m ade for at least the minimum**  **response time of the instrument. When monitoring operations involving a descent into atmospheres**  **that may be stratified, the atmospheric envelope should be tested a dista nce of approximately four**  **feet in the direction of travel and to each side. If a sampli ng probe is used, the rate of progress**  **should be slowed to accommodate the sampling speed and detector response . Any reading greater than zero should be followed by an assessment to:**  **1. Determine the source of the flammable vapors; 2. Eliminate the source, if possible; and**  **3. Ensure control of the source so that concentrations will not exceed ( at most) 10% of the LEL**  **at any location where it is possible that an ignition source may be present**

**.** Continuous or Follow-Up Monitoring **Continuous or follow-up monitoring may be required under conditions where the process, sequence**  **of work instructions or ambient conditions might reasonably be expec ted to change in a manner that**  **might increase the concentration of flammable gas or vapor. If conditions change during the course**  **of the permit period in a way that presents or could present ad ditional hazards, then work will be**  **terminated until the area or conditions are made safe and permit conditions are re -evaluated.**  **Processes that may affect the composition, concentration, flow ra te or volume, pressure and/or**  **temperature of flammable liquids, vapors or gases; 1. Processes adjacent to the process at which hot work is being performed;** **DEECO Health and Safety Plan Page 41 January 2010**

**2. Ambient conditions such as temperature, wind direction and wind speed; and 3. Other factors, such as the presence of uncontrolled vehicular traff**  **ic and/or ignition sources.** Documentation of Results (Record Keeping) **Each monitor obtained by DEECO will be assign a unique equipme nt identification (control) number**  **and complete records, including periodic performance, calibration and maintenance checks will be**  **maintained.** 2.29 Emergency Response/Evacuation Program **While at a client’s facility, follow their Emergency Respons e/Evacuation Program. The project**  **manager/field team leader will ensure that the employees a re aware of the facilities’ Emergency**  **Response/Evacuation Program. Their plan should address the following; 1. Procedures for reporting a fire or other emergency;**  **2. Procedures for emergency evacuation, including type of evacuation and e xit route**  **assignments; 3. Procedures to account for all employees after evacuation (head count);**  **4. Procedures to be followed by employees performing rescue or medical duti es; and**  **5. The name or job title of every employee who may be contacted by employees who need more**  **information about the plan or an explanation of their duties under the plan. Otherwise, when working at DEECO’s office, the following Emerge**  **ncy Response/Evacuation procedures should be followed;**  **1. Report a fires or other emergencies by dialing 911. Administer first aid and/or CPR if you**  **trained. Do not attempt to fight any fires unless you have been tr ained in the use of fire**  **extinguishers; 2. Should an evacuation be necessary follow the escape route assignme**  **nts. Exit diagrams are place throughout the office to identify the escape routes to be foll**  **owed by employees from each specific facility location. Assist in the evacuation of any visitors and cont**  **ractors; 3. Account for employees after the evacuation to ensure that everyone**  **got out. Designated employees will sweep areas, checking offices and rest rooms, b**  **efore being the last to leave a workplace or conducting a roll call in the assembly area; and**  **4. Account for any visitors and contractors using the Visitors and Contractors Sign In Log**

**. DEECO Health and Safety Plan Page 42 January 2010** 

2.30 Compressed Air Systems **DEECO employees are not allowed to operate pneumatic powe r tools or use the compressed air**  **systems, air hoses, or air lines associated with pneumatic power tools.**

2.31 Concrete Construction **DEECO employees are not allowed perform any concrete work, as described in OS HA 1926.700-**  **706.**

2.32 Powder-Actuated Tools **DEECO employees are not allowed to use powder-actuated tools, as described in OSHA 1926.302**  **(e). DEECO Health and Safety Plan Page 43 January 2010** 



### 3.0 Chemical Safety Guidelines **The procedures and guidelines detailed in the following sections are to be used by DEECO Field**  **personnel while performing work on either DEECO or client premis es. If the client has additional**  **safety procedures, Field personnel are to follow the procedures whi ch are more stringent. In all**  **cases, all OSHA and/or EPA requirements shall be met. Field personnel are to refer to the Material Safety Data S**  **heet and chemical labels for specific procedures and handling requirements. Copies of MSDSs for each chem**  **ical used, as well as for each chemical Field personnel may be exposed to while on a client's site, must b**  **e made available. The client is responsible for ensuring that MSDSs for chemicals us**  **ed on the work site are available for review. All Field personnel should refer to these MSDSs and be**  **familiar with the properties and handling requirements of all chemicals that may be used or encountered.**  **The required level of personal protective equipment for specific chemical hazards discussed in the**  **following sections depends on the situations at the work site. Decis ions on the appropriate**  **equipment to be worn should be made by the project manager or coordinator. The following information is DEECO's Chemical Hygiene Plan. Its intent**  **is to protect laboratory employees from health hazards associated with the use of hazardous**  **chemicals in our laboratory and to assure that our laboratory employees are not exposed to substances in exc**  **ess of the permissible exposure limits as defined by OSHA in 29 CFR 1910 subpart Z.**  **The plan is available to all employees fro review and a copy will be located in the Health and Safety**  **files. The plan will be reviewed annually by the Health and Sa fety Officer and/or the directors of**  **DEECO. The following sections of this document and throughout the manual are sta**  **ndard operating procedures for which each DEECO employee has received adequate tr**  **aining and direction. If questions exist for the following information, it may be found throughout**  **this manual or in our memo file. It is the responsibility of each employee to be**  **aware of DEECO's standard operating procedures for the following:**  **Accidents, spills, avoidance of routine exposure, choice of chemicals , eating-drinking-smoking,**  **equipment and glassware, horseplay, mouth suction, personal apparel, house keeping, personal**  **protection, planning, unattended operations, use of the hood, waste disposal a nd storage, working**  **alone, corrosives, fires, explosions, low temperature, pressurized and vacuum operations,**  **compressed gasses, chemical storage. The following operations shall be performed in the LABORATORY FUME HOO**  **D: - Use of solvents unless in outdoor work areas**  **- Use of open flames or burning devices - Use of any organic or inorganic chemical or compound that is unstable**  **These include preparation of standards, transfer of solvents, disposal or consolidat ion of waste** **DEECO Health and Safety Plan Page 44 January 2010**

**Respirators shall be used in accordance with DEECO's respira tory protection policy and with the**  **OSHA respirator standard 29 CFR 1910.134. This policy and associated docum entation is filed in**  **the office of the Health and Safety Officer and/or safety files. Appropriate protective apparel compatible with the required de**  **gree of protection for substances handled shall be used. The Health and Safety Officer is availab**  **le to advise employees on glove, gown, eye protection, barrier creams, etc, use. Permeability**  **Charts are available in any safety catalog such as Lab Safety Supply, or SAFECO. Use of tradenames or r**  **eferences does not indicate a recommendation or approval of listed products or Companies.**  **All eyewash stations are clearly marked and identified by the use of green placards and red arrows**  **leading to the eyewash areas. Employees who need to use the eyewashes are ins tructed as to their**  **use and must irrigate for a minimum of 15 minutes and seek medical assistance immediately.**  **Eyewashes will be inspected by the safety officer every month. Employees have been issued a memorandum as to the procedures to foll**  **ow for fires and explosions. Exit routes are marked in each employee area.**  **Fume hoods will be inspected every six months by the Health and Sa fety Officer. Adequacy of face**  **velocity will be determined by the use of a propeller anemome ter and must reach a minimum of 200**  **fpm. An employee may request a hood inspection at any time should t hey suspect a problem with**  **the hood or ventilation system. No employee will work with any hazardous chemicals unless they have**  **been instructed by their project manager or health and safety officer. These chemic**  **als include; carcinogens, explosives, neurotoxins, reproductive damaging chemicals, or acutely hazardous chemicals.**  **DEECO shall provide, to affected employees, medical attention inc luding follow-up examinations**  **which MEDFIRST or another approved medical office determines is ne cessary under the following**  **circumstances. a. whenever an employee develops signs and/or symptoms associate**  **d with a hazardous chemical to which they may have been exposed, the employee shall**  **be provided an opportunity to receive appropriate medical examination. The emp**  **loyee shall contact the Health and Safety Officer to initiate the medical program.**  **b. Where exposure monitoring reveals an exposure level routinely ab ove the OSHA action level**  **(AL) (or in the absence of an action level, exposure above the OSH A permissible exposure**  **level (PEL)) for OSHA regulated substances for which there a re medical monitoring**  **requirements, medical surveillance shall be established for tha t employee. Listed OSHA**  **standard medical surveillance requirements include the chemical be nzene, formaldehyde,**  **methylene chloride. c. Whenever an event takes place in the laboratory or work area suc**  **h as a spill, leak, explosion, or other occurrence resulting in the likelihood of a hazardous exposure,**  **the affected employee, laboratory or custodial, shall be provided an opportunity for**  **a medical consultation. This consultation is for the purpose of determining**  **the need for a medical examination.** **DEECO Health and Safety Plan Page 45 January 2010**

**All aspects of these examinations are provided by a licensed p hysician, or supervised by a licensed**  **physician. These examinations are provided without cost to the empl oyee, without loss of pay, and**  **at a reasonable time and place. The Health and Safety Officer who is also the Chemical Hygie**  **ne Officer will provide information to the physician:**  **1. Identity of the hazardous chemical to which the employee may have been exposed. 2. A description of the conditions of the exposure including exposure date if available**  **3. A description of the signs and symptoms of exposure that the employee is experiencing (if**  **any). The physician's written opinion shall include:**  **1. Recommendations for future medical follow-up 2. Results of examination and associated tests**  **3. Any medical condition revealed that may place the employee at inc reased risk as the result**  **of a chemical exposure. 4. A statement that the employee has been informed by the physic**  **ian of the results and told of any medical conditions that may require additional examination of treatment.** 

3.1 General Characteristics Routes of Entry **There are three major routes through which chemicals can enter the body and potentially cause harm.** 

Inhalation: **Contaminants in the air can be absorbed into the bloodstream dire ctly through the**  **lungs. In this manner, the contaminant can be carried to any organ in the body.** Ingestion: **Ingestion of chemicals may severely damage the tissues of the digestive tr act, damage**  **the stomach or other organs. The chemical can be absorbed into the bloodstream, or other body**  **fluids, and carried to other organs in the body.** Skin Absorption: **The skin can act as a protective barrier to many chemical agents. However, many**  **chemicals can penetrate the skin. In this manner, the chemicals can enter the bloodstream and be**  **distributed throughout the body. Wounds on the skin (e.g. cuts and abrasions) offer a di rect route**  **for chemicals to enter the bloodstream.** Physical Characteristics of Chemicals **Below are definitions of terms used in the following Chemical Sa fety Sections. Additional**  **definitions are located in the Guide to Common MSDS Terms, located in Appendix C. Gas - a formless fluid which takes the shape of its container.**  **Vapor - the gaseous form of a substance which is normally a solid or liquid a t room** 

**temperature. Fog - a visible, liquid aerosol.**  **Mist - a "fog" where the liquid particles are large enough to be individually s een.**  **Fume - particle formed by the condensation of vaporized solids. DEECO Health and Safety Plan Page 46 January 2010** 

**Dust - solid particles, capable of temporary suspension in air. Smoke - airborne particles generated from incomplete combustion process**  **es. Carcinogen - a substance capable of causing cancer in animals or humans.**  **Mutagen - a substance capable of changing the genetic material in a livi ng cell.**  **Fetotoxin - a substance capable of causing death or injury to fetus. Teratogen - a substance which can cause deformations in a fe**  **tus from exposure of a**

**pregnant female.**

Health Hazards **Substances to which field employees may be exposed have the potential to cause severe injury or**  **illnesses. The degree of injury or illness is a function of the exposure; that is the amount of the**  **substance and the time that an employee is in contact with it. Below are descriptions of various types**  **of health hazards that may exist when working with hazardous substances.**

Irritant: **Several chemicals may be an irritant to the skin, eyes, or respir atory tract. Irritation can**  **range from mild discomfort to severe and irreversible chemical burns on the skin or eyes. Examples**  **of irritants include ammonia, acids, bases, and several solvents.**

Sensitizer: **A chemical that is a sensitizer may not elicit a res ponse after one exposure. After**  **repeated exposures, however, a severe reaction may occur, not necess arily at the point of contact.**  **The reaction may be a skin rash, or in the case of toluene diisocya nate, failure of the respiratory**  **system, Examples of sensitizers are formaldehyde, poison ivy, potassium di chromate.** 

Narcotic: **Narcotics cause a depression of the central nervous system, pr oducing a sleepy or dizzy**  **effect. Narcotics may make an employee unable to perform his /her work. Other safety hazards arise**  **when employees affected by a narcotic attempt to continue to work. Most organic solvents can**  **produce narcotic effects.** Asphyxiant: **An asphyxiant reduces the amount of oxygen available for use by the body. This can**  **cause suffocation, leading to coma or even death. There are two typ es of asphyxiants. A Simple**  **Asphyxiant reduces the amount of oxygen in an area. Examples of simple asphyxiants include**  **carbon dioxide, nitrogen, argon, and other inert gases. A second type of asphyxiant is called a**  **Chemical Asphyxiant. A chemical asphyxiant enters the body thr ough the lungs, and competes with**  **oxygen for space in the red blood cells. With these asphyxiants, suffocation can occur even if there**  **is plenty of oxygen in the room. Examples of chemical asphyxia nts include carbon monoxide, and**  **cyanide gas.** Systemic Poison of Toxin: **A systemic poison or toxin is a substance that produces an af fect away**  **from the point of contact. For instance carbon tetrachloride can be inhaled or absorbed through the**  **skin, but exhibits its major effects upon the liver and kidneys. It is important to remember that different chemicals react**  **differently with the body. Several chemicals exhibit more than one effect. The employee must re**  **view the MSDS for the specific chemical he/she is working with to fully understand all of the potential hazards.** **DEECO Health and Safety Plan Page 47 January 2010**

3.2 Acids
Potential Hazards Routes of Entry - Inhalation, Ingestion, Contact **1. Acids are corrosive substances having a pH < 7.0. 2. Acid vapors and fumes can cause irritation of the eyes, skin, and respiratory trac**  **t. 3. Chemical burns on tissue can occur if acids are allowed to contact skin, eyes, or lung**  **s. 4. Severe gastrointestinal pain and tissue injury can occur if acids are inge**  **sted.** Symptoms of Overexposure **Hazards of exposure are mainly from acute (short duration) exposur es. Effects of acid fumes**  **or vapors include eye, throat, nose, or lung irritation. Skin or eye cont act with acids may**  **result in severe chemical burns.**

First Aid **In the event that acid comes in contact with your skin or eyes:** # **Proceed immediately to the nearest eyewash station. Call for assistance from a co**  **worker if necessary.** # **Flush the affected area with copious amounts of water for at least 15 minutes. If**  **contact was with eye, pull the eyelid up and out, exposing the corne a, while flushing**  **with water.** # **Notify the project manager or coordinator and seek medical attention. If acid is spilled on your clothing:**  # **Remove contaminated clothing immediately.** # **Flush skin area with water for 15 minutes.** # **Notify the manager or coordinator and seek medical attention. Personal Protective Equipment**  **1. Gloves (Disposable Latex or Nitrile) 2. Protective Clothing (Saranex Tyvek Suits)**  **3. Respiratory Protection - Minimum or a half-mask, air-purifying respirator with Acid Gas or**  **Organic Vapor/Acid Gas Cartridges. 4. Eyewear - Minimum of safety glasses with side shields.**  **Recommend chemical splash goggles.** 

3.3 Bases
Potential Hazards Routes of Entry - Inhalation, Ingestion, Contact **1. Bases are corrosive substances having a pH > 7.0. 2. Vapors and fumes generated from bases can cause irritation of**  **the eyes, skin, and respiratory tract.** **DEECO Health and Safety Plan Page 48 January 2010**

**3. Chemical burns can occur if bases are allowed to contact skin or eyes. Bases can cause**  **irreversible damage to the eyes, even in dilute concentrations. 4. Severe gastrointestinal pain and tissue injury can occur if bases are i**  **ngested.** Symptoms of Overexposure **Hazards of exposure are mainly from acute (short duration ) expo sures. Effects of alkali**  **fumes or vapors include eye, throat, nose, or long irritation. Skin or ey e contact with bases**  **may result in severe chemical burns.**

First Aid **In the event that a base comes in contact with your skin or eyes:** # **Proceed immediately to the nearest eyewash station. Call for assistance from a co**  **worker if necessary.** # **Flush the affected area with copious amounts of water for a t least 15 minutes. If**  **contact was with eye, pull the eyelid up and out, exposing the cornea.** # **Notify the project manager or coordinator and seek medical attention. If a base is spilled on your clothing:**  # **Remove contaminated clothing immediately.** # **Flush skin area with water for 15 minutes.** # **Notify the project manager or coordinator and seek medical attention.** Personal Protective Equipment **1. Gloves (Disposable Latex or Nitrile) 2. Protective Clothing (Saranex Tyvek Suits)**  **3. Respiratory Protection - Minimum or a half-mask, air-purifying respirator with Acid Gas or**  **Organic Vapor/Acid Gas Cartridges. 4. Eyewear - Minimum of safety glasses with side shields. Rec**  **ommend chemical splash goggles.**  3.4 Compressed Gases
Potential Hazards Routes of Entry - Inhalation, Contact **1. Cylinders may explode if heated above 135** E **F or dropped, damaging the valve stem. 2. Fire Hazards may exist if a Flammable Gas, Oxygen or ot**  **her oxidizing gas cylinder is placed near an open flame.**  **3 Skin and eye burns may result if direct contact with an escaping gas is made. 4. Suffocation can occur if the concentration of a gas is allowed**  **to decrease the percent of oxygen in an area.**  **5. If Oxygen is allowed to be released, it may be absorbed int o clothing and take as long as 15**  **minutes to disperse. This could lead to a flash clothing fire if the person comes in contact**  **with an ignition source. 6. Severe burns may result from skin or eye contact with cryogenic gases.** **DEECO Health and Safety Plan Page 49 January 2010**

**7. Prolonged breathing of oxygen can be toxic. 8. A fire or explosion hazard may exist when using nitrogen and helium**  **, since these gases can condense oxygen from the air, creating an oxygen-rich environment at t**  **he location of the gas.** Symptoms of Overexposure **Symptoms of overexposure to compressed gases depends on the specific gas. Ref er to the**  **MSDS of the gas for this information.** General Handling Procedures **1. Cylinders should be tagged with a FULL, IN USE, or EMPTY Status Tag at all t imes.**  **2. Cylinders must have the valve protection cap in place when being moved. 3. Cylinders shall be stored such that they are protected from ex**  **cessive heat or open flame (125**

E **F), physical shock, and electrical circuits. 4. Cylinders shall be secured using a chain or strap, to a wall, bench or other firm**  **support. 5. Never completely empty a gas cylinder.**  **6. Never use oil on regulator valves or connections. Oil can degrade the regulator diaphragm,**  **contaminate the gas, or be oxidized in air to form explosive products. 7. Use only CGA (Compressed Gas Association) approved regulators**  **and fittings for the specific gas being used. Do not mix a given regulator with different gases.**  **8. Do not tamper with manufacturer's safety devices or check valves. 9. Leak-test all fittings and connections using an appropriate leak-test solut**  **ion. 10. Jewelry should not be worn when handling or using cryogens.**  **11. If a cylinder should develop a leak:** # **Remove all sources of spark or flame.** # **Place in exhausted enclosure or remove to a safe outdoor area.** # **Identify the cylinder as "Leaking Cylinder". Notify the supplier.** # **For Flammable Gases, attach a control valve to the cylinder valve and allow the gas**  **to escape. Adjust to a moderate discharge rate. 12. If a cylinder containing cryogenic gases is dropped:**  # **Evacuate area within 100-ft radius of cylinder;** # **Keeping a safe distance (no less than 50 feet), determine if the cylinder's inner vessel**  **relief valve is venting, or if the outer vessel bursting disc ha s ruptured. If either is**  **venting gas, do not approach until there is no further discharge.** # **When emission from the cylinder has not been noticed for 15 minutes, car efully open**  **the vent valve and the gas withdrawal valve to empty the cylinder. Move away from**  **the cylinder after opening valves.** # **Once emptied, place in upright position. Write "Dropped Cylinde r" on the cylinder**  **status tag and notify the supplier.**

First Aid **If skin or eye contact occurs, flush area with unheated water and apply cold compresse s.** **DEECO Health and Safety Plan Page 50 January 2010**

Personal Protective Equipment **Safety glasses should be worn at a minimum. Cryogenic gloves shoul d be worn if contact with a**  **cryogenic gas is possible.** 3.5 Cryogenic Materials **Cryogenic materials are substances that are kept at very low tempera tures (less than 100**  E **F). Cryogenics may be liquids or solids. Atmospheric gases, such as**  **nitrogen, oxygen, or hydrogen, that are cooled to temperatures less than 150**  E **F become liquified and are examples of cryogenic materials. "Dry Ice" is another example of a super-cooled gas, carbon dioxi**  **de.**

Potential Hazards Routes of Entry - Contact, Inhalation **1. Severe burns may result from skin or eye contact with cryogenic materials**

**. 2. Some liquid gases can deplete the available oxygen in a room S**  **uffocation can result if not used in a well-ventilated area.**  **3. Prolonged breathing of pure oxygen may have harmful physiological effects**

**. 4. Nitrogen and helium can condense oxygen from the air, creating an oxy**  **gen-rich environment at the location of the gas. This could be a fire or explosion hazard.**  **5. Cryogenic gases are stored under high pressure. This creates the same potential hazards as**  **other compressed gases (see Section 3.4). 6. Hydrogen is extremely flammable and is a fire and explosion hazard.**  **7. Liquid oxygen, while not flammable itself, does increase the fla mmability of ordinary**  **combustibles.** General Handling Procedures **1. When there is the potential for contact with a cryogenic mate rial, a full face shield will be**  **required. In addition, a lab coat and gloves suitable for cold materi al handling shall be worn.**  **2. Jewelry should not be worn when handling or using cryogens. 3. When handling cryogens, trousers should not have cuff.**  **4. Use tongs to remove objects that are immersed in cryogenic li quids. Never use your hands,**  **even if wearing gloves!! 5. Use only in well-ventilated areas.**  **6. Store away from flammable and combustible materials. 7. Do not use near open flame or spark-producing equipment.**  Emergency Procedures **1. If skin or eye contact occurs, flush area with unheated water and a pply cold compresses.**  **Notify your supervisor and seek medical attention. 2. If a cylinder containing cryogenic gases is dropped:**  # **Evacuate area within 100-ft radius of cylinder; DEECO Health and Safety Plan Page 51 January 2010** 

# **Keeping a safe distance (no less than 50 feet), determine if the cylinder's inner vessel**  **relief valve is venting, or if the outer vessel bursting disc has ruptured. If either is**  **venting gas, do not approach until there is no further discharge.** # **When emission from the cylinder has not been noticed for 15 minutes, car efully open**  **the vent valve and the gust withdrawal valve to empty the cylinder. Move away from**  **the cylinder after opening valves.** # **Once emptied, place in upright position. Write "Dropped Cylinde r" on the cylinder**  **status tag and notify the supplier.** 3.6 Flammable Liquids and Gases
Potential Hazards Routes of Entry - Inhalation, Ingestion, Contact **1. Flammable liquids and gases pose significant fire and explosion hazards. 2. Many flammable liquids:**  # **Can be readily absorbed through the skin.** # **Can cause dermatitis.** # **Are systemic poisons once in the body. 3. Eye, skin and respiratory tract irritation may occur.**  **4. Many flammable liquids and gases can produce depression of the c entral nervous system**  **(decreases motor response, dizziness, etc.)** Systems of Overexposure **Symptoms of overexposure to flammable liquids and gases will de pend on the specific**  **substance. Refer to the MSDS of the chemical for this information.**

General Procedures **1. Keep flammable materials away from open flame, sparks, or excessi ve heat.**  **2. Keep away from oxidizing agents such as oxygen. 3. Store in chemical cabinet, isolated from other chemicals.**  **4. Keep combustible material such as wood, cloth, and paper out of storage cabinet s.**  **5. Do not leave containers of flammable materials in work areas overnight. Return all bottles**  **to the proper storage cabinet. 6. Flammable liquids and gases should be used only in well ventilated areas.** 

First Aid **1. If skin or eye contact occurs, flush affected area with water for 15 minutes. Remove**  **contaminated clothing. Seek medical attention. 2. In the event of a burn; extinguish flames by applying a fire blanket, or roll**  **ing on the floor. Do not attempt to fan out the flames.**  **3. Use only an approved fire extinguisher to extinguish flames. Do not use water on flammable**  **liquid fires. Pouring water on these fires may only spread the flames over a wider area.** **DEECO Health and Safety Plan Page 52 January 2010**

Personal Protective Equipment **1. Gloves (Disposable Latex or Nitrile) 2. Eyewear - minimum of safety glasses with side shields. Che**  **mical goggles required if there is a potential for splash.**  3.7 Organic Solvents
Potential Hazards Routes of Entry - Inhalation, Ingestion, Contact **1. Solvents can cause skin, eye and respiratory tract irritation. 2. Solvents may cause defatting of the skin, which lessens the abi**  **lity of the skin to protect against other chemicals.**  **3. Some solvents are also systemic toxins and can produce effects on the liver, kidneys, and**  **other organs if allowed to be absorbed through the skin. 4. Inhalation of solvent vapors may produce narcotic or anesthetic effe**  **cts, and depression of the central nervous system.**  **5. Many organic solvents are also flammable.** Symptoms of Overexposure **Symptoms of overexposure to solvents will depend on the specific su bstance. Refer to the**  **MSDS of the chemical for this information.**

General Procedures **1. Use solvents only in local exhaust hood or well ventilated areas. 2. Do not continue to work if you feel dizzy or sleepy. Have a co-worke**  **r secure your apparatus (turn off heat, close containers, etc.) and escort you away from the area.** 

First Aid **1. If skin or eye contact occurs, flush affected area with water for 15 minutes. Remove affected**  **clothing. 2. If dizziness occurs from inhalation, get to fresh air.**  **3. In the event of a spill:** # **Turn off all sources of flame or sparks. Keep area well ventilated.** # **Small spills can be handled by using a solvent spill kit. 4. Use only an approved fire extinguisher to extinguish flames. D**  **o not use water on liquid fires. Pouring water on these fires may only spread the flames over a wider are**  **a.** Personal Protective Equipment **1. Gloves (Disposable Latex or Nitrile) 2. Eyewear - minimum of safety glasses with side shields. Che**  **mical goggles required if there is a potential for splash.** **DEECO Health and Safety Plan Page 53 January 2010**

3.8 Oxidizing Agents
Potential Hazards Routes of Entry - Inhalation, Ingestion, Contact **1. Oxidizing agents can be irritating to skin, eyes, and the respiratory trac t.**  **2. Most oxidizing agents are highly reactive, and may react violentl y with metals, as well as**  **other chemicals. 3. Oxidizers are corrosive and can cause burns on skin and eyes.**  **4. Oxidizers spontaneously evolve oxygen, and therefore may create a fire on explosion hazard**  **in some environments.** Symptoms of Overexposure **Symptoms of overexposure to solvents will depend on the specific sub stance. Refer to the**  **MSDS of the chemical for this information.**

General Procedures **1. Do not mix with organic solvents. 2. Always store in unbreakable, inert containers.**  **3. Do not use cork or rubber stoppers. 4. Respiratory protection is required when handling chlorine or bromine gas.**  **5. Label containers of oxidizers with the date received, and the date the container was first**  **opened.**

First Aid **1. If skin or eye contact occurs, flush affected area with water for 15 minutes. Remove affected**  **clothing. 2. In the event of a spill:**  # **Turn off all spark and open flame sources.** # **Cover spill area with a bisulfite solution. Mix well and spra y with water. Place**  **waste in container with water. 3. If a gas leak occurs, remove all sources of spark or flame.**  **Place cylinder in an exhausted enclosure or remove it to a safe outdoor area as soon as possible.**  Personal Protective Equipment **1. Gloves (Disposable Latex or Nitrile) 2. Eyewear - minimum of safety glasses with side shields. Che**  **mical goggles required if there is a potential for splash.** 

3.9 Asbestos Awareness **Asbestos is the name applied to six naturally occurring minera ls that are mined from the earth.**  **Because it is so hard to destroy asbestos fibers, the body cannot break the m down or remove them**  **once they are lodged in lung or body tissues. They remain in place where they can caus e disease.**  **There are three primary diseases associated with asbestos exposure: Asbestosis**  **Lung Cancer Mesothelioma** **DEECO Health and Safety Plan Page 54 January 2010**

**DEECO personnel may be exposed to asbestos while on a client's premises. The most common use**  **of asbestos at our client’s facilities is insulation on pipe s and vessels. Asbestos boiler insulation**  **does not present a hazard unless the protective covering is c ut or damaged in such a way that the**  **asbestos underneath is actually exposed to the air. The project manager/field team leader will ensure**  **that the client has identified or provided means to identify asbestos-containing e quipment.**  **If you do not know whether something is asbestos or not, assume that i t is until it is verified**  **otherwise.**

**DO NOT DISTURB IT. Never...**  **Drill Hammer**  **Cut Saw**  **Break Damage**  **Move Disturb**  **...any asbestos-containing materials or suspected materials.**

3.10 Benzene Awareness **Benzene is a volatile chemical formed from both natural processe s and human activities. Natural**  **sources of benzene include emissions from volcanoes and forest fires. Benzene is also a natural part**  **of crude oil, gasoline, and cigarette smoke. Benzene is widely used i n the United States, ranking in**  **the top 20 chemicals for production volume. It is primarily used as a solvent, as a starting material**  **for the production of other chemicals, and as a gasoline additive. Brea thing benzene can cause**  **drowsiness, dizziness, and unconsciousness; long-term benzene exposure ca uses effects on the bone**  **marrow and can cause anemia and leukemia. The Occupational Safety and Health Administration**  **(OSHA) recognizes benzene as a hazardous material and imposes strict exposure limits in the**  **workplace. It is unlikely that DEECO personnel would be exposed to benzene on a**  **client's premises at levels above the OSHA permissible exposure limits (1 ppm TWA for 8**  **hour and 5 ppm STEL for 15 minutes). If the potential for benzene exposure exists, the proje**  **ct manager/field team leader will ensure that the client has identified regulated areas where the**  **permissible exposure limits could be exceeded.**  **DEECO does not use benzene for any sample recovery procedures.** 3.11 Hydrogen Sulfide Awareness **Hydrogen sulfide (H 2**  **S) is a colorless gas with a powerful nauseating smell of rot ten eggs. The odor**  **is a poor warning property because hydrogen sulfide exposure quickly dea dens the sense of smell.**  **The gas is heavier than air and may collect in low areas such a s sewers, pits, tunnels or gullies. High**  **airborne levels of hydrogen sulfide (between 4.3 and 46.0 percent of gas by volume in the air) may**  **catch fire if there is a source of ignition. If the gas is burned, toxic p roducts such as sulfur dioxide** **DEECO Health and Safety Plan Page 55 January 2010**

**will be formed. Hydrogen sulfide is incompatible with oxidizing a gents, such as nitric acid and**  **chlorine trifluoride, and may react violently or ignite spontaneously. Hydrogen sulfide is extremely toxic. It may cause death instant**  **aneously in high airborne concentrations. Low levels may be extremely irritating to the lungs, nose, throa**  **t and eyes. Hydrogen sulfide can be detected by smell at levels as low as**  **0.13 parts hydrogen sulfide per million parts air (ppm). Odor cannot be used as a warning because the ga**  **s can deaden the sense of smell within 2 to 15 minutes in exposures of approximately 100 ppm. A single**  **breath of hydrogen sulfide at about 1000 ppm may paralyze the respiratory system and resul**  **t in coma and death. Convulsions may also occur. Prolonged exposure at about 250 ppm hydrogen sulfide may cause t**  **he lung tissue to swell and fill up with water (pulmonary edema).**  **This effect may occur after the exposed worker recovers from t he irritant effects of the gas.**  **Exposures of 20 to 50 ppm hydrogen sulfide for one hour may cause inflamma tion of the cornea and**  **the delicate lining of the eye and eyelid (a condition called kerat oconjunctivitis). Exposures for long**  **periods at 50 ppm may cause severe irritation of the nose, throat and lungs. Workers exposed to**  **lower concentrations of hydrogen sulfide may develop headaches, eye disorders and chronic**  **bronchitis. DEECO personal may be exposed to hydrogen en sulfide on a client's**  **premises at levels above the OSHA permissible exposure limits (20 ppm (ceiling) with the**  **following exception: if no other measurable exposure occurs during the 8-hour work shift, exposures may**  **exceed 20 ppm, but not more than 50 ppm (peak), for a single time period up to 10 minutes.).**  **Small amounts of hydrogen sulfide occur in crude petroleum but natural gas can contain up to 90%**  **. By far the largest industrial route to H**  **2 S occurs in petroleum refineries. Other sources of hydrogen sulfide**  **include coke ovens, paper mills (using the sulfate method), and tanneries. H**  **2 S arises from virtually anywhere where**  **elemental sulfur comes into contact with organic material, especially at high temperatures.**  **Should the potential exist for exposure to H 2**  **S, the project manager/field team leader will work with the client to ensure that all personnel are provided with the following training;**  **1. Identification of the characteristics, sources, and hazards of Hydrogen Sulfide, 2. Proper use of the Hydrogen Sulfide detection methods used on the site,**  **3. Recognition of, and proper response to, Hydrogen Sulfide warnings at the workplac e,**  **4. Symptoms of Hydrogen Sulfide exposure, 5. Proper rescue techniques and first-aid procedures to be used in a**  **Hydrogen Sulfide exposure, 6. Proper use and maintenance of personal protective equipment. Demons**  **trated proficiency in using PPE should be required,**  **7. Worker awareness and understanding of workplace practices and mai ntenance procedures**  **to protect personnel from exposure to hydrogen sulfide, 8. Wind direction awareness and routes of egress,**  **9. Confined space and enclosed facility entry procedures. 10. Locations and use of safety equipment,**  **11. Locations of safe briefing areas, 12. Use and operation of all Hydrogen Sulfide monitoring systems, and**  **13. Emergency response procedures, corrective action, and shutdown procedures. DEECO Health and Safety Plan Page 56 January 2010** 

**At most client facilities where hydrogen sulfide exposure coul d occur, this training is required by**  **the client prior to entry.**

3.12 Lead Awareness **Lead is a toxic metal that was used for many years in products found in and around our homes. Lead**  **also can be emitted into the air from motor vehicles and industria l sources, and lead can enter**  **drinking water from plumbing materials. Lead may cause a range of health effects, from behavioral**  **problems and learning disabilities, to seizures and death. Childre n six years old and under are most**  **at risk. Most Common Sources of Lead Poisoning:**  **1. Deteriorating lead-based paint, 2. Lead contaminated dust, and**  **3. Lead contaminated residential soil DEECO personal may be exposed to lead hazards created by renova**  **tion, repair and painting (RRP) activities at client facilities that disturb lead-based pa**  **int. The lead exposure limit is fifty micrograms per cubic meter of air (50 ug/m**  **3 ) averaged over an 8-hour period. The project manager/field team**  **leader will ensure that the client has identified any areas wh ere the potential for exposure to lead**  **exists and access these areas by DEECO employees will be prohibi ted.** **DEECO Health and Safety Plan Page 57 January 2010**



### 4.0 Hazard Communication Requirements

Introduction **The Occupational Safety and Health Administration's (OSHA) Ha zard Communication Regulation**  **(29 CFR 1910.1200) requires that employees be informed of all hazardous che micals located in their**  **workplace. This program will describe how DEECO intends to protect the safe**  **ty and health of our employees who are exposed to hazardous chemicals in the workplace, and to compl**  **y with the provisions of 29 CFR 1910.1200.**  **Each supervisor will be held responsible for strict adherence to these policies and will closely**  **monitor all activities involving hazardous chemicals. Each employee will carefully follow established work practic**  **es and promptly report observed or potential problems to supervision.**  **There is no job at DEECO so vital or urgent as to justify the risk of employee overexposure to a**  **hazardous chemical. Ask when in doubt. Proceed with a job only afte r being satisfied that it is safe**  **for you to do so. A list of all hazardous chemicals for each workplace has been made and is re**  **adily available, upon request, to any employee, working on any shift. It is located in eac**  **h tow vehicle, shop area, and wet chemistry lab.**  **DEECO is responsible to ensure that the list of hazardous chemic als is kept current and that a current**  **MSDS for each hazardous chemical used is on hand. A chemical that is not shown on the curre nt**  **list will not be ordered without prior coordination with the wet chemistry lab m anager.**  **All containers of hazardous chemicals in each workplace will be conspicuously labeled with the**  **identity of the chemical, and the appropriate hazard warnings. I f the chemical is a known or**  **suspected carcinogen, or it is known to affect a specific organ of the body, this information will also**  **be placed on the container label. The person having supervisory re sponsibility for the storage or use**  **or each hazardous chemical will ensure that such labels are not de faced and that they remain legible**  **at all times. The health and safety officer will ensure that an adequate supply of labels are on hand**  **and made available to the responsible supervisors. When an outside contractor is used, it will be the responsibility**  **of the project manager to advise the contractor of any hazardous chemical to which their employees may**  **be exposed and the appropriate protective measures to be taken. This procedure also works conversely.**  **All employees exposed to any hazardous chemicals will complet e an information and training**  **program which includes at least the subjects listed below. New employee s must complete similar**  **instructions before initial exposure to any hazardous chemical in the workplac e.** **DEECO Health and Safety Plan Page 58 January 2010**

**Adequate training of all employees exposed to hazardous chemicals will be given by the Health and**  **Safety Officer or an approved training instructor and assisted as needed by the Hazard**  **Communication Program Monitor. Employee information for this program will include:**  **1. The purpose and need for such a program, including the basic concept that gives every employee**  **the right to know about hazardous chemicals with which they work. 2. The location and availability of the written Hazard Communicati**  **on Program, plus the list of hazardous chemicals and their corresponding MSDS's.**  **3. The identity upon request, of any chemical to which the emp loyee id exposed. In the case of a**  **trade secret chemical, the name on the MSDS will be provided. Employee training shall include at least the following:**  **1. Methods and observations used to detect the presence or release of a hazardous chemical in the**  **work ares such as monitoring devices, appearance, or odor. 2. The physical and health hazards associated with each chemical, as specifie**  **d in the MSDS. 3. Action that employees can take to protect their own safety and**  **health, including specific procedures that have been established for normal work practices, e**  **mergency procedures, and policies on the use of personal protective equipment.**  **4. Details of the Hazard Communication Program, including an explanat ion of the labeling system**  **used on in-house containers of hazardous chemicals. Also, details of how e mployees can obtain and**  **use information contained in the MSDS. It is the intent of DEECO management to protect the safety a**  **nd health of each employee, our most valuable and valued asset. By following correct procedures, no employ**  **ee should experience and harmful effects from working with chemicals in their workplace.**  Client Responsibilities **Clients are required to inform DEECO personnel working on the premi ses of all hazards located in**  **the area. In addition to chemical hazards, the client should inform DEECO:** # **Location of all emergency exits.** # **Location of nearest medical facilities.** # **Location of nearest emergency equipment (fire extinguishers, sa fety showers,**  **eyewashes, etc.) The client should have available for DEECO personnel MSDSs on al**  **l chemicals located in the area(s) where DEECO will be performing work.**  **The team leader should ensure that the above information is obtained before s etting up equipment**  **to perform the work. DEECO Health and Safety Plan Page 59 January 2010** 

DEECO Responsibilities **DEECO is required to inform its employees of all hazards that they may contact. MSDSs for each**  **chemical used by the Field Division are available in the centra l MSDS file located at the field office.**  **DEECO must also supply the client, upon request, information on the chemicals which DEECO**  **brings on the client's premises to perform field work. MSDS s are present prior to entering the**  **client's premises.** Written Program **The OSHA regulation requires that DEECO have a written Hazard Communication Program. The**  **written program for the Field Division is located in Appendix D of this Health and S afety Plan.**  4.1 Material Safety Data Sheets **The manufactured or distributor of chemicals used by DEECO is required to supply DEECO with**  **a MSDS. Employees must be informed of the information on the MSDS prior to working with a**  **chemical. A MSDS must exist for all hazardous chemicals. MSDSs for che**  **micals used on a client's site must be available for review or photocopying by the client. A lis**  **t of all chemicals brought on site by DEECO should be supplied to the client. The client should be informed that a MSDS**  **is available for each chemical on that list.**  **Hazardous materials that require a MSDS are substances whic h may present a physical or health**  **hazard. A material presents a** Physical Hazard **if it is:** # **Flammable** # **Combustible** # **Explosive** # **Reactive** # **Under Pressure A material presents a**  Health Hazard **if it is:** # **Corrosive** # **An Irritant** # **A Sensitizer** # **A Carcinogen** # **Harmful to body organs, including skin, eyes, reproductive organs, liver , kidneys,**  **lungs, blood, or nervous system. Each MSDS is required to provide the user with the following information:** 

Section I **- Supplier Information. This section must include the manufacturer 's name, address, and**  **an emergency telephone number. Also included in Section I is the nam e of the chemical as it appears**  **on the chemical label. Synonyms for the chemical name may also be given. DEECO Health and Safety Plan Page 60 January 2010** 

Section II **- Hazardous Ingredients Information. This section will list all the hazardous ingredients**  **of the chemical if they constitute 1% of the mixture or more. If the hazardous ingredient is a**  **carcinogen (capable of causing cancer), the ingredient will be listed if it constitutes 0.1% of the**  **mixture or more. Also listed for each ingredient will be the p ercentage that it makes up of the**  **mixture, and its current permissible exposure level (PEL).**

Section III **- Physical/Chemical Characteristics. This section will l ist characteristics such as boiling**  **point, vapor pressure, specific gravity, melting point, vapor densit y, evaporation rate, and solubility**  **in water. The substance's appearance and odor characteristics will also b e given.** 

Section IV **- Fire and Explosion Hazard Data. Included in this section will be the chemical's flash**  **point, flammability limits (upper and lower), the correct typ e of material to use to extinguish a fire,**  **any unusual fire and explosion hazards, and any special fire fighting procedures.**

Section V **- Reactivity Data. This section will list any conditions that should b e avoided with this**  **chemical, whether or not the chemical is stable, substances the chemical is incompatible with, any**  **hazardous decomposition products or any hazardous polymerization that may occur.**

Section VI **- Health Hazard Data. Information included in this section will be possible routes of**  **exposure, signs and symptoms of overexposure (both acute and chromic exposures), medical**  **conditions that may be aggravated by exposure to this chemical, and emergency first aid.** 

Section VII **- Precautions for Safe Handling. This section will list step s to be taken in the event of**  **a spill or release of the chemical, the proper waste dispos al methods, and any precautions that should**  **be taken during handling and storage.**

Section VIII **- Control Measures. Included in this section will be the proper personal protective**  **equipment (respiratory protection, gloves, eye/face protection), t he required ventilation system, and**  **other work practices that should be followed when using this chemical.**

Section IX - **Additional Information. This section will list any other pertinent information such as**  **transportation requirements or where to get other information regarding the chemi cal.**  4.2 Chemical Labelling **All chemicals used in the field or at DEECO must be labelle d. Chemical containers received from**  **the manufacturer are required to contain the chemical's name, hazar d warnings, and the**  **manufacture's name and address. This manufacturer's label may not be defaced in any manner.**  **Beakers and other containers used by DEECO employees must also b e clearly labelled with the**  **chemical name at all times. Several chemical manufacturers place the NFPA (National Fir**  **e Protection Association) hazard label on the bottle. This label identifies some of the hazardous properties of the che**  **mical. Transfer containers used by more than one employee must be label**  **led. Chemical formulas must not be used (for example, use "Acetone" instead of CH**  **3 COCH**  **3 ).** **DEECO Health and Safety Plan Page 61 January 2010**

4.3 Employee Exposure Monitoring **In order to ensure that field personnel are not overexposed to hazar dous materials, the DEECO**  **Safety Officer may direct the Project Manager or Coordinator to perform employee exposure**  **monitoring. Results from monitoring surveys will be forwarded to the departme**  **nt managers. The manager must review the report with each employee in the department. This c**  **an be accomplished by reviewing the report in a department meeting or circulating the report t**  **o all employees. Employees must sign an Employee Notification Form which accompanies the report. The**  **employees' signatures indicate that the report was reviewed and understood by each employee. The de**  **cision to monitor employee exposure will be made on a project-by-project basis by the DEE**  **CO S.O. and the Project Manager or Coordinator.**  **The department managers must retain copies of all monitori ng reports. These reports should be**  **reviewed with all new employees, or employees being reassigne d to the area, before allowing the**  **employee to work in the area. Employees may review past sampling reports that are repr**  **esentative of their exposure by contacting their department manager, the Director of Personnel, or the DEECO S.O.**  4.4 Employee Medical Surveillance **DEECO requires each employee to take a pre-employment physical. This physical establishes the**  **employee's physical condition before performing work at DEECO. In addition, DEECO field**  **employees will receive annual physicals based upon their job descrip tion and age.**  **Employees may receive additional medical evaluation if:** # **Signs or symptoms associated with exposure to a hazardous chemica l at DEECO**  **develop.** # **Routine exposure monitoring indicate that employee exposure exceeds the**  **Permissible Exposure Level or Action Level for a given substance.** # **A spill, leak or other event occurs which may have resulted in exp osure to a**  **hazardous exposure. These physicals will be provided during normal working hours (when poss**  **ible) and at no cost to employees. Copies of all medical evaluations will be forwar**  **ded to the Director of Personnel for placement in the employee's confidential, personal file. Physic**  **al evaluations made under the above conditions shall not reveal findings of diagnoses unrelated to the employ**  **ee's occupational exposure. Employees may at any time, review all medical information on f**  **ile by contacting either the department manager or the Director of Personnel.**  4.5 Employee Access to Records **Employees may be asked to participate in chemical exposure monitoring. DEECO will maintain**  **records of employee medical surveillance, exposure monitoring, and oc cupational accidents or**  **injuries. As per OSHA regulations, this information may be re viewed by employees by requesting** **DEECO Health and Safety Plan Page 62 January 2010**

**the information from the Area Supervisor, Manager or the Personnel Director. A copy of the OSHA**  **standard regarding access to exposure and medical records may be obtained from the DEECO S.O.**  **Responsibilities The DEECO Safety Officer must ensure that:**  # **All employee exposure monitoring reports are reviewed by emp loyees, and that**  **employees acknowledge the receipt of the reports by signing the report.** # **Copies of the signed report are sent to the Personnel Director.** # **Other information, such as MSDSs, ventilation records, etc. are mai ntained for at**  **least 30 years. The Personnel Director must ensure that:**  # **Employee medical, exposure and accident/injury records are maint ained for the**  **length of employment plus thirty (30) years.** # **A response to any internal and external requests for medical or exposure records is**  **given within 15 working days. The Department Managers must ensure that:**  # **Employees review and sign all Employee Exposure reports.** # **Employees are advised of the right to access medical and exposur e records annually**  **in a department safety meeting. DEECO Health and Safety Plan Page 63 January 2010** 



### 5.0 Personal Protective Equipment **The procedures and guidelines detailed in the following sections are to be used by DEECO Field**  **personnel while performing work on either DEECO or client premis es. If the client has additional**  **requirements for personal protective equipment, field personnel are to follow the procedures which**  **are more stringent. In all cases, all OSHA and/or EPA require ments are to be met. Field personnel**  **are not to use personal protective equipment for which they have not r eceived adequate training in**  **their use and limitations. Protective equipment, including personal protective equipment for eye**  **s, face, head, and extremities, protective clothing, respiratory devices, and protective shields and**  **barriers, will be provided, used, and maintained in a sanitary and reliable condition wherever it is**  **necessary by reason of hazards of processes or environment, chemical hazards, radiological hazards, or m**  **echanical irritants encountered in a manner capable of causing injury or impairment i**  **n the function of any part of the body through absorption, inhalation or physical contact.**  **Where employees provide their own protective equipment, DEECO wil l be responsible to assure its**  **adequacy, including proper maintenance, and sanitation of such equipment. All personal protective equipment shall be of safe design and c**  **onstruction for the work to be performed. The protective equipment, including personal protective**  **equipment (PPE) will be provided by DEECO at no cost to employees. DEECO will pay for**  **replacement PPE, except when the employee has lost or intentionally damaged the PPE.**  5.1 Respiratory Protection **Detailed information regarding the use of specific respirators is located in the DEECO Field Division**  **Written Protection Program.**

Use **Only employees that have been trained in the use of respiratory protection shall select or wear**  **respirators. Employees must:** # **Be fit-tested and trained annually.** # **Ensure that equipment is clean, available, and in good repair.** # **Use equipment only as instructed.** # **Receive medical clearance to wear a respirator.** # **Not have beards, long side-burns, or other conditions that may preclude a good face**  **to-facepiece seal.** # **Ensure that the proper respirator cartridge or canister i s used for a particular**  **contaminant. All cartridges are marked and color-coded. When donning the respirator:**  # **Place mask on face with chin in chin-cup.** # **Attach lower straps around neck.** # **Place top straps on crown of head, above ears.** # **Tighten all straps. DEECO Health and Safety Plan Page 64 January 2010** 

**Each time the respirator is conned, positive and negative pressure fit-chec ks must be performed.**  **Positive Pressure Fit-Checks:** # **Place the palm of hand over the exhalation valve.** # **Exhale gently. The mask should lift off the face without allowing the air to escape.**  **Negative Pressure Fit-Checks:** # **Cover the inlets of the cartridges with hands.** # **Inhale gently. The mask should collapse around the face without letti ng air in around**  **the face-to- respirator seal.**

Selection **Respirators provide specific Protection Factors based on the type to res pirator and the cartridge or**  **canister in use. The Protection Factor is defined as the concentra tion of an air contaminant outside**  **the mask divided by the concentration of that some contaminant inside the mask. For example, the**  **half-mask respirator with HEPA (High Efficiency Particula te Absolute) filter cartridge has a**  **Protection Factor of 10. This indicates that if worn in an area with a concentra tion of 0.05 mg/m**  **3 of airborne lead, the employee would actually be exposed to 0.005 mg/m**  **3 of lead.**  **Employees should select the type of respirator and cartridge ba sed on the decision criteria located**  **in the DEECO Respiratory Protection written program.** Inspection **Employees must inspect each respirator prior to donning. Straps , inhalation and exhalation valves,**  **cartridge gaskets, and facepiece should be inspected to ensure al l parts are present, clean and in good**  **condition.**

Decontamination **Respirator should be cleaned after each use. Remove cartridges and place the m in a plastic bag.**  **Wash respirator with warm, soapy water. Rinse the respirator thoroughly since soap can be a skin**  **irritant. Allow respirator to air dry. Place in plastic bag when dry and store in dry location away**  **from excessive heat. Do not place anything on top of respirator since this may distort the facepiece.**  Breathing Air Quality and Use **When DEECO employees are required to use atmosphere-supplying r espirators (supplied-air and**  **SCBA), DEECO will ensure that compressed air, compressed oxyg en, liquid air, and liquid oxygen**  **used for respiration accords with the following specifications: 1. Compressed and liquid oxygen shall meet the United States Pharma**  **copoeia requirements for medical or breathing oxygen;**  **2. Compressed breathing air shall meet at least the requireme nts for Grade D breathing air**  **described in ANSI/Compressed Gas Association Commodity Specificati on for Air, G-7.1-**  **1989, to include and oxygen content (v/v) of 19.5-23.5%, a hydrocarbon (condensed) content of 5 milligrams per cubic meter of air or less, a carbon m**  **onoxide (CO) content of 10 ppm or less; a carbon dioxide content of 1,000 ppm or less; and lack of noticeable odor.** **DEECO Health and Safety Plan Page 65 January 2010**

**DEECO will ensure that compressed oxygen is not used in atmosphe re-supplying respirators that**  **have previously used compressed air and ensure that oxygen concentrati ons greater than 23.5% are**  **used only in equipment designed for oxygen service or distribution. DEECO will ensure that cylinders used to supply breathing air**  **to respirators meet the following requirements:**  **1. Cylinders are tested and maintained as prescribed in the Ship ping Container Specification**  **Regulations of the Department of Transportation (49 CFR part 173 and part 178); 2. Cylinders of purchased breathing air have a certificate of ana**  **lysis from the supplier that the breathing air meets the requirements for Grade D breathing air; and**  **3. The moisture content in the cylinder does not exceed a dew point of - 50 deg.F (-45.6 deg.C)**  **at 1 atmosphere pressure. DEECO will ensure that compressors used to supply breathing ai**  **r to respirators are constructed and situated so as to:**  **1. Prevent entry of contaminated air into the air-supply system; 2. Minimize moisture content so that the dew point at 1 atmosphere**  **pressure is 10 degrees F (5.56 deg.C) below the ambient temperature;**  **3. Have suitable in-line air-purifying sorbent beds and filters to further ensure breathing air**  **quality. Sorbent beds and filters shall be maintained and replace d or refurbished periodically**  **following the manufacturer's instructions; 4. Have a tag containing the most recent change date and the signatur**  **e of the person authorized by the employer to perform the change. The tag shall be maintained at the comp**  **ressor. For compressors that are not oil-lubricated, the DEECO will e**  **nsure that carbon monoxide levels in the breathing air do not exceed 10 ppm.**  **For oil-lubricated compressors, the DEECO will use a high-tem perature or carbon monoxide alarm,**  **or both, to monitor carbon monoxide levels. If only high-temperature ala rms are used, the air supply**  **shall be monitored at intervals sufficient to prevent carbon monox ide in the breathing air from**  **exceeding 10 ppm. The DEECO will ensure that breathing air couplings are incomp**  **atible with outlets for non-respirable work site air or other gas systems. No asphyxiating substance**  **shall be introduced into breathing air lines.**  **DEECO will use breathing gas containers marked in accordance wi th the NIOSH respirator**  **certification standard, 42 CFR part 84. DEECO Health and Safety Plan Page 66 January 2010** 

5.2 Gloves
Use & Selection **Gloves should be worn when there is a potential for skin contact, suc h as pouring chemicals,**  **washing glassware with solvents, collecting samples, etc. Dif ferent gloves protect against different**  **chemicals. The glove compatibility chart below should be consulted when selec ting gloves.**  Inspection **Employees must check the gloves before donning by:** # **Inspecting for cracks, holes, or tears.** # **Performing a leak test by grasping the cuff of the glove quic kly such that air is**  **trapped inside the glove. Squeeze the glove to ensure that air ca nnot escape. If a**  **glove has any hole, crack, or tear, or has evidence of degradation to the material,**  **discard the glove. Employees must ensure that an ample supply of the proper glove**  **s are always available in the field.**

Decontamination **Employees should rinse gloves with water before removing. Gloves s hould be turned inside-out**  **during removal. Contaminated gloves are to be discarded.**

Glove Selection Chart Chemical(s) Glove Type **Solvents Nitrile (Sol-Vex) -Chlorinated PVA**  **Acids, Bases Nitrile (Sol-Vex)**

**Neoprene (Stanzoil) PVC Coated**  **Sample Collection Disposible Latex** 5.3 Protective Eyewear
Use & Selection **Chemical and physical hazards in the field have the potential to p roduce injuries to the eye and face.**  **These injuries could seriously impair or destroy vision, or permane ntly destroy facial skin. DEECO**  **provides eye and face protective equipment to employees at no cost. It is the responsibility of the Field Coordinator and Field Employees to ensure tha**  **t proper eye and face protection is available and worn in the work area. Contact**  **lenses may not be worn in areas requiring safety glasses.** **DEECO Health and Safety Plan Page 67 January 2010** Eyewear Hazards **Safety Glasses To be worn at all times on the work site or in designated "Eye** 

**Protection Required" areas. Safety Goggles To be worn whenever there is a potential of a che**  **mical splash**

**(e.g. handling or pouring solvents.) Face Shields To be worn when handling or pouring acids, bases, or other** 

**corrosive chemicals; when there is a potential of flying debris from drilling, cutting or grinding materials with power tools.**  Inspection **All safety glasses must meet the American National Standar ds Institute (ANSI) Standard Z87.1.**  **Safety glasses are required to have "Z87.1" stamped on the inside of the frame, or etched on the**  **lenses. DEECO will provide prescription safety glasses to those employees that require corrective**  **lenses. Safety glasses, goggles, or face shields that show visible si**  **gns of deterioration or damage should be repaired or discarded. If a damaged item is to be repaired, i**  **t should be placed in a plastic bag, sealed, and labeled "DAMAGED EQUIPMENT: FOR REPAIR".** 

Decontamination **All safety eyewear should be thoroughly cleaned with soap and wate r after each use in a**  **contaminated, or potentially contaminated, area.** 5.4 Protective Clothing **In many work situations it may be necessary for field personnel to wear full body protective clothing.**  **The Project Manager or Coordinator should identify the types of pr otective clothing that may be**  **necessary for a particular project, and ensure that the equipme nt is available at the work site. Brief**  **descriptions of the various protective clothing materials are given be low. In most situations, only**  **Tyvek or Saranex clothing will be necessary.** Standard Tyvek (non-porous) **Non-woven, olefin fiber fabric. Suitable for protection against m ost dusts, mists, and fumes.**  **Fabric melts at temperatures above 270** E **F. Should not be used to protect against solvent vapors or acid gases/fumes.**  Saranex Tyvek **Standard Tyvek which has one side coated with saranex plastic. This gives the clothing a**  **high level of resistance to most hazardous chemicals, including PCBs . Should not be used**  **in temperatures above 270** E **F. DEECO Health and Safety Plan Page 68 January 2010** 

Polyethylene Coated Tyvek **Standard Tyvek which has one side coated with polyethylene. This gives the clothing a high**  **level of resistance to most hazardous chemicals, including PCBs. M ore resistent to moisture,**  **and will protect individuals against chemical spills and spla shes better than the Saranex**  **Tyvek. Should not be used in temperatures above 270** E **F. Protective clothing is available in other materials, such as pol**  **yvinyl chloride, neoprene, Viton, and butyl rubber. These materials protect against a higher degr**  **ee of hazard than Field personnel would be expected to encounter. If the Project Manager or Coordinator f**  **eels that additional protection is required for a specific project, he/she should discuss clothing options with the S**  **.O.**

5.5 OSHA Levels of Protection
Use & Selection **Employees should select the level of personal protective equipment required for each individual**  **work site based on the current EPA guidelines below. Employees are not to perform tasks in the**  **work area if the proper personal protective equipment is not ava ilable or in good working condition.**  **At a minimum, employees must wear safety glasses and safet y shoes/boots at all work sites. DEECO**  **employees will not enter areas requiring Level A or Level B protection. All employees will be**  **trained on the proper use of protection equipment for Level C and Level D protect ion.** 

Levels of Protection **Level A - Highest level of respiratory, skin and eye protection is needed. Criteria inc**  **lude:**

# **High concentration of vapors, gases or particulates.** # **High potential for splash, immersion or potential exposure to hi ghly toxic**  **materials.** # **Confined or poorly-ventilated areas. Equipment:**  # **Supplied air respirator (pressure-demand SCBA or airline re spirator with** 

**escape bottle)** # **Fully encapsulating chemical resistent suit** # **Inner gloves, chemical resistent** # **Chemical resistent safety (steel-toe and shank) boots Optional Equipment includes coveralls, long cotton underwear, hard hat, disp**  **osable gloves and boot covers, cooling unit, 2-way radios.**  **Level B - Highest level of respiratory protection, lesser level of skin protecti**  **on. Criteria include:**

# **Atmospheres immediately dangerous to life and health (IDLH)** # **Oxygen deficient atmosphere (<20%).** # **Low potential for splash, immersion or potential exposure to highl y toxic**  **materials. DEECO Health and Safety Plan Page 69 January 2010** 

**Equipment:** # **Supplied air respirator (pressure-demand SCBA or airline res pirator with** 

**escape bottle)** # **Chemical resistent clothing** # **Outer gloves, chemical resistent** # **Inner gloves, chemical resistent** # **Chemical resistent safety (steel-toe and shank) boots Optional Equipment includes long cotton underwear, hard hat, disposable gloves and**  **boot covers, cooling unit, 2-way radios.**  **Level C - Conditions allow the use of air-purifying respirators. Criteria include:** 

# **Oxygen concentrations not less than 20%.** # **Concentrations of identified contaminants will be reduced by the respi rator**  **below the contaminants TLV, and the concentration is within the se rvice limit**  **of the canister/cartridge.** # **Concentrations of contaminants to not exceed IDLH levels.** # **Low potential for splash, immersion or potential exposure to highl y toxic**  **materials.** # **FID or PID measurements show concentrations only a few ppms above background.**  **Equipment:** # **Air-purifying, full-face respirator with appropriate canister or ca rtridges** 

# **Chemical resistent clothing** # **Outer gloves. Chemical resistent** # **Chemical resistent safety (steel-toe and shank) boots Optional Equipment includes long cotton underwear, hard hat, disposable gloves and**  **boot covers, escape mask, hard hat, 2-way radios.**  **Level D - No respiratory or skin hazards exist. Criteria include:** 

# **No contaminants present.** # **No potential for splash, immersion or potential exposure to any chemicals. Equipment:**  # **Coveralls or work clothing**

# **Safety shoes/boots** # **Safety glasses** # **Hard hat Optional Equipment includes gloves, face shield.** **DEECO Health and Safety Plan Page 70 January 2010**

5.5 Training for the Use Personal Protective Equipment **DEECO will provide training to each employee who is required to use PPE. Each s uch employee**  **will be trained to know when PPE is necessary, what PPE is necessary, how to properly don, doff,**  **adjust, and wear PPE, the limitations of the PPE, and the proper care, maintenance, useful life and**  **disposal of the PPE. Each affected employee will be required to demonstrate an underst**  **anding of the training and the ability to use PPE properly, before being allowed to perform work requi**  **ring the use of PPE. When DEECO has reason to believe that any affected employee who**  **has already been trained does not have the understanding and skill required, DEECO will retrain each such employee.**  **Circumstances where retraining is required include, but are not li mited to, situations where changes**  **in the workplace render previous training obsolete, changes in th e types of PPE to be used render**  **previous training obsolete, or inadequacies in an affected employee 's knowledge or use of assigned**  **PPE indicate that the employee has not retained the requisite understanding or skill**

**. DEECO will verify that each affected employee has received and**  **understood the required training through a written certification that contains the name of each emp**  **loyee trained, the date(s) of training, and that identifies the subject of the certification.**